Healthcare providers who submit claims this week will be crossing their fingers that the switch to national provider identifiers will go smoothly and that reimbursements will follow without any disruptions to their cash flow.
The Centers for Medicare & Medicaid Services didn't deliver any last-minute delays for the use of NPIs, which went into effect on Friday, May 23. CMS already had delayed for one year a deadline to use NPIs only on claims forms.
This past year, providers were allowed to use both NPIs and legacy identification numbers on claims while continuing to test procedures that would enable a full transition to NPIs.
Providers were nervous amid reports of transition difficulties and a recent survey by a large transaction solutions provider indicating that, if payers were sticklers about NPI use, as many as a third of claims submitted by providers could technically be rejected.
Concerns about readiness led 37 industry organizations to sign a letter at the start of this month asking Health and Human Services Secretary Michael Levitt to allow six additional months for the industry to make the transition to NPI-only claims.
As of Friday, Medicare fee-for-service payers require and send NPI-only claims in all provider identifier fields for all HIPAA and paper transactions where a provider identifier is required. Providers who send Medicare a transaction with a Medicare legacy identifier in any of the provider fields will have claims rejected.
Transactions include all electronic and paper claims, including the 837I, 837P, NCPDP, DDE and paper CMS-1500 and UB-04; the 276/277 claim status transaction; the 270/271 eligibility transaction; and the 835 remittance advice and SPR paper remittance.
CMS officials said providers must attempt to obtain NPIs from secondary providers in cases where those providers don't supply them. The billing provider may use the NPI registry to obtain the secondary provider's NPI or it may need to contact that provider to get the NPI.
In cases where providers can't get the secondary provider's NPI, a provider can use its own NPI as the identifier for the secondary provider, because Medicare payers will reject claims in cases where a secondary identifier is required and no NPI is present.
Obtaining NPIs from secondary providers could be a stumbling block for implementation, according to a study by Emdeon Business Services.
In a study of NPI use on claims it received the week of May 12, Emdeon found that the use of NPIs declines noticeably when secondary providers are required.
"Medicare's guidance has been for providers to copy their own rendering NPI number/name and place into those fields on Medicare claims," Emdeon officials said. "However, providers will not be able to use that approach for all claims, as some payers will require the actual NPI of the secondary providers on the claim."
Emdeon reviewed 1.9 million institutional claims and found that nearly 4.9 percent were missing the NPI of the billing provider.
NPIs were missing on 9.4 percent of claims for billing provider and pay-to-provider, when present.
Emdeon officials concluded that if payers strictly require NPI data for all providers included in claims, they could reject almost 34 percent of claims, "leading to cash flow issues for providers."