Even with a contingency plan in place to give the healthcare industry time to implement national provider identifiers, the federal government is keeping the pressure on to move the industry to adoption.
Medicare expects to begin reject some older paper claim forms, which don't have spaces for NPIs, before the end of this month, and some providers may face claims rejections if NPIs are not included.
Vagaries in the transition plan appear to be increasing uncertainty for some community-based providers, such as home care agencies, hospices, long-term care providers and others that submit claims that are signed by referring physicians. Those claims must contain physicians' NPIs, and that's a problem if physicians are lagging behind in obtaining and sharing their standardized identifiers.
Providers participating in a Medicare Fee-For-Service NPI Contingency Plan roundtable discussion Thursday afternoon brought up a number of difficult situations they expect to face in submitting claims to Medicare. Officials from the Centers for Medicare & Medicaid Services were sympathetic, but indicated that the grace period for the transition is not intended to support inactivity.
"Doctors better get out there and get their NPIs really fast," said Marlene Biggs, the NPI fee for service lead in the office of information services.
During the transition period, CMS will allow both the use of NPIs and legacy identifiers on Medicare claims, said Aryeh Langer, health insurance specialist in the provider communications group for CMS. However, it's unclear how long CMS will permit use of both identifiers.
"We'll allow legacy numbers until a sufficient number of providers are using NPI," Biggs said. "At this time, we don't have a clearly defined number. We're looking at a number of factors regarding adoption, and we don't have a specific statistic in mind at this point.
"We want to implement NPI as quickly as we can without adversely affecting providers," Biggs added.
The contingency plan for implementing NPIs, required under HIPAA regulations, would give providers a maximum of one year to make the transition, pushing the deadline back to as late as May 22, 2008.
When CMS believes a sufficient number of providers are able to make the transition, it will announce when it will reject Medicare claims without NPIs. Providers will get sufficient warning before CMS moves solely to the NPI.
CMS will enforce the move to NPIs based on complaints. Providers that are the subject of complaints must show progress in obtaining NPIs, testing data exchanges and crosswalks with existing legacy identifiers, Langer said.
CMS said it will begin rejecting UB-92 claims forms after May 22, and it will begin rejecting the 12/90 version of the HCFA 1500 claims form after July 1. Instead, providers will need to use UB-04 forms and the 0805 version of the HCFA 1500 form. The new forms accommodate the reporting of NPIs.
Also, CMS will return only NPI numbers on remittance forms after October 1, dropping reference to legacy identification numbers at that point.