Bulletin: April 6, 2007

CMS’ NPI Contingency Plan

By: Marketing Specialist

On April 2, 2007, CMS announced its contingency plan for covered entities that do not meet the National Provider Identifier (NPI) compliance regulations by the May 23, 2007 deadline, except for small plans, which have a compliance date of May 23, 2008. According to HIPAA, the final rule on adopting NPI as the only healthcare provider identifier states that all covered entities must be in compliance with the NPI provisions by this deadline. In order to comply with HIPAA standards, covered transactions that require a healthcare provider’s identifier must not contain legacy identifiers during transmission, and only NPIs.

During this transitional period, CMS evaluates a covered entity’s compliance standards and enforcement policies based on “good faith efforts.” If it appears that an entity (non-small plan) has demonstrated good faith in its attempts to comply with the May 23, 2007 deadline of NPI implementation, CMS will refrain from imposing any penalties. When enforcing compliance, CMS will use a complaint-driven approach. If a complaint has been filed against a covered entity for failure to comply with an NPI provision, CMS will notify the entity of the complaint in writing. The entity must then display to CMS its continuing effort in good faith towards compliance, and develop and employ a contingency plan to avoid any enforcement penalties. Each covered entity determines the specifics of its contingency plan, which may not continue after May 23, 2008. However, the entities may end their contingency plan before this date.

CMS decided to announce its implementation approach and clarify the NPI rule guidelines after it became apparent that numerous covered entities would be unprepared to fully comply with the NPI standardization by May 23, 2007. The establishment of the contingency plan provides covered entities protection from enforcement penalties if they continually demonstrate to CMS their reasonable and diligent efforts toward compliance.

Quadax continues its preparation for the May 23, 2007 deadline and is transmitting NPIs to those payers ready to accept them, on behalf of those providers who have submitted and registered their NPIs to our database. It is critical that all provider clients notify Quadax of their NPIs, and learn NPIs for referring and other physicians whose numbers are needed to complete your claims. Obtain your NPI, register it with Quadax and your contracted payers, and use it on your claims to keep your cash flow intact and allow Quadax to maintain its successful processing of your claims.