NPI Redux

William D. Rogers, MD, FACEP

Dr Rogers is Medical Officer, Office of the Administrator, and Director, Physicians Regulatory Issues Team, Centers for Medicare & Medicaid Services, Department of Health and Human Services

When I wrote my first article about the National Provider Identifier (NPI) number a few months ago, the implementation deadline was a long way away, the data dissemination notice was imminent, and life was good. Now the deadline has passed, 2 contingency notices have been released, and the data dissemination notice was released months later than we had hoped. Where are we now with the NPI?

First, a brief review. Since Congress enacted the Health Insurance Portability and Accountability Act (HIPAA) in 1996, many provisions have been enacted, designed to improve the efficiency of the healthcare system, including sections 261 through 264, which require the Secretary of Health and Human Services to publicize standards for the electronic exchange, privacy, and security of health information.

The privacy rule released in 2002 required most practices to replace their paper claims with electronic billing. The deadline for implementing electronic billing was ultimately extended to October 1, 2005.

Other HIPAA provisions are still in the process of being implemented. One of these is adopting the NPI as the standard unique health identifier for all healthcare providers. In April 2005, the Centers for Medicare & Medicaid Services (CMS) signed a contract with Fox Systems, designating them the enumerator. Most physicians have since been enumerated, with about 2.2 million NPIs assigned to date. The deadline for using the NPI on Medicare claims was May 23, 2007.

Start Using Your NPI

CMS now wants you to put your NPI on all claims. You should be using your NPI with your legacy number to allow the development of a crosswalk so that your claims can be paid promptly.

CMS is aware that physicians also often need the NPIs of fellow practitioners. To facilitate such information sharing, CMS requires that covered entities share their NPIs on request with organizations that need the number for billing purposes.

The NPI is not a secret number. If a hospital or a lab asks your office staff for your NPI to generate a bill for clinical services, your office staff should feel comfortable sharing this number. And wouldn't it be convenient if your office staff could look up any NPI online? The Data Dissemination Notice explains how your staff can look up an NPI. You can read this notice at: www.cms.hhs.gov/NationalProvIdentStand/Downloads/DataDisseminationNPI.pdf.

CMS also has an online lookup capability that allows your staff to find the NPI of the physician who requested the consult you have just completed.

The Physician's Regulatory Issues Team has been hearing from many physicians and other covered entities about challenges they have encountered as they implement NPI requirements. We are particularly sensitive to the unexpected costs some practices have encountered when they learned they had to upgrade their computers before they could install billing software that could handle the NPI. It is unfortunate that the law that created the NPI did not budget money to

help physicians comply with the requirement.

When to Contact the NPI Enumerator

Remember that the NPI enumerator can only answer/address the following types of questions/issues:

• Status of an NPI application, update, or deactivation
• Forgotten/lost NPI
• Lost NPI notification letter
• Trouble accessing the National Plan and Provider Enumeration System
• Forgotten password/user ID
• Need to request a paper application
• Need for clarification on information that is to be supplied in the NPI application.

Physicians needing this type of assistance may contact the enumerator at 800-465-3203, TTY (TeleTYpewriter for hearing/speech impaired) 800-692-2326, or e-mail your request to: .

For assistance with any issues or concerns, contact us at or call 202-690-5907. ?