The NationalProvider Identifier (NPI) process started with the HIPAA legislation which was passed in 1996 and included Administrative Simplification provisions in that law. At the time, many providers said “that would be great to have only one number to keep track of�. Little did we realize the significant impact this process could have on the revenue cycle of both providers and insurers.

As with all new initiatives, we first must learn the language. Most of you are familiar with issues surrounding HIPAA initiative. The Administrative Simplification provisions attached to this bill have driven the largest unfunded regulatory mandate ever to the health care industry. The idea of standard transactions is great, but the implementation of an initiative of this magnitude is slowed by political positioning and industry lobbies.

• NPS – National Provider System – The legislative process directing the registration of providers and maintaining a national data base.
• NPI – Nation Provider Identifier – Unique number assigned to all providers.
• NPPES – National Plan and Provider Enumerations System – The data base and registration of providers.

Since May 2006, providers have registered for their NPI numbers resulting in about two thirds of providers registered by the end of June. The initial deadline for submitting only the NPI number as your unique provider number was May 23, 2007. The slow response of providers and the technology struggles of carriers caused CMS to issue extensions past the May 23, 2007 deadline. The purpose of the extension was to assure that providers with NPI numbers, would still get paid after the May 23rd deadline. Many insurance carriers (commercial and government) were not ready to accept ONLY the NPI number on claims so they were given a new deadline of May 2008, as long as they had an acceptable implementation plan.

The NPPES data base was to be completed by the end of 2006 so providers could access this data base to look up an NPI number just like we look up UPIN numbers now. That data base has not been published due to disagreement on how the data should be shared and what pieces of data would be valid. The result of this failure to publish and pass regulations in 2006 is that carriers have no data base to test their software changes against. As a result, the burden of sharing these numbers has fallen squarely on providers without adequate governmental support.

The biggest challenge that you as providers have had is upgrading your software to send the NPI numbers in electronic claims or on paper claims versus the five digit UPIN number. Implementing the National Provider Identifier required all software companies to retool and accommodate a 10 digit identifier for all providers (9 digits identify the provider with 10th check digit to help prevent fraud). If your software conversion has not been made, this is your break to get that finished.

There are a few ways to increase the probability that your reimbursement for services does not decline in this process.

1. Do a standard fax cover sheet – one page with your NPI and taxonomy codes for your practice and all the providers and share it.
2. Check the insurance carrier websites to determine how they want the information from NPPES regarding your NPI and assigned Taxonomy codes, and make sure your information is accurate in their data base.
3. Make sure your vendor starts sending both the NPI number and your current numbers on claims as soon as possible. This insures that the numbers crosswalk correctly with Medicare and with other carriers. On May 23rd several major carriers reported less than 10% of claims being submitted with an NPI number.
4. Develop a spread sheet now with the fee schedule from all your carriers for your top 50 CPT codes. You will need to verify that all payments are at the same fee schedule as the carrier makes their transition. If your numbers did not crosswalk accurately in the carrierÂ’s data base, you could get paid at a lower fee schedule.
5. If you find that your fee schedule does not cross over accurately, call the carrier immediately. If you need to appeal claims, then print them on colored paper with a cover sheet to each claim that says “NPI Crosswalk error – Claim paid inaccurately�.
6. Check your information in the NPPES data base. You were issued a user ID and password when you registered. Make sure your data is accurately entered and if you disclosed your Social Security Number, you can delete that from your profile.
7. Monitor claim response reports that have an error saying “NPI NOT ON CROSSWALK IN 2010AA LOOP� which indicates that the reported NPI number does not match the legacy number in the carrier system. You will need to call the carrier to resolve this crosswalk issue.

Medicare has not released the date when only NPI numbers will be required. The date will be based on the volume of claims that are received with both numbers over the next few months. Those practices that have an NPI implementation strategy will be more successful in maintaining cashflow during this transition.

For additional information about the NPI process, visit theCMS website at: http://www.cms.hhs.gov/NationalProvIdentStand/

https://nppes.cms.hhs.gov/NPPES/Welcome.do

http://www.cms.hhs.gov/home/outreacheducation.asp

Carol has an extensive background in both clinical operations and in revenue cycle management. Along with her nursing experience, she spent 20 years with a health care company in Maryland and as the COO was responsible for all aspects of the revenue cycle. Currently she is the National Training Director for MedPay USA, LLC which furnishes sophisticated tools for revenue cycle management, and she is the owner of CJ Consulting. She is one of the founders of the StraightTalk Seminar series here in San Antonio. You can reach her at: carol@CJConsultingHelp.com.