Provider groups, reacting to uncertainty surrounding the use of national provider identifiers on claims forms, are asking the government to delay enforcing use of the numbers after May 23.
Various organizations, including the National Uniform Billing Committee and National Uniform Claims Committee, have sent a letter to Health and Human Services Secretary Mike Leavitt asking for the additional extension for the NPI requirement.
Without the delay, providers could face penalties for continuing to use legacy identifiers on the bills for services they submit to Medicare and other payers. This year's May 23 deadline already was delayed a year as part of a contingency plan issued last April.
The letter from provider organizations followed the announcement in early April that the Centers for Medicare & Medicaid Services that it was not able to match a healthcare organization's national provider identifier with multiple legacy numbers. As a result, the CMS advised providers to obtain a separate NPI for each segment, or subpart, of their organizations.
That announcement, paired with the stated intent of Medicare to no longer accept legacy numbers submitted on Medicare claims, could cause a major cash flow crisis for providers, said George Arges, chair of the National Uniform Billing Committee and senior director of the health data management group of the American Hospital Association.
"At this point in time, it's almost imperative to have this continuation," Arges said. "If CMS is trying to meet a date for the sake of meeting a date, it will come on the backs of providers' cash flow."
National provider identifiers - a way to numerically label providers with a unique tag - were required as part of the administrative simplification provisions of the Health Insurance Portability and Accountability Act of 1996. However, the process has been anything but simple. CMS encountered problems and delays with the process, administered through the National Plan and Provider Enumeration System, resulting in the implementation of a contingency plan, giving the nation's plans and providers a year - until May 23, 2008 - to test to ensure that providers' NPIs and legacy numbers were mapped.
NPIs are issued both for individual providers, such as physicians, and for organizations, which could also request separate NPIs for units within the organization, such as psychiatric and rehabilitation units within hospitals.
CMS encountered problems in early April when it tried to crosswalk a provider's NPI to each of its subparts through the reporting of taxonomy codes in the claims. As a result, claims could be suspended and not paid by fiscal intermediaries, CMS reported. As a workaround, CMS suggested on April 3 that providers obtain NPIs for their subparts.
While obtaining additional NPIs isn't difficult through the NPPES, it creates additional administrative burden and introduces a late entry of uncertainty into the claims submission process, because there is limited time to test the new numbers.
In announcing the problems with subpart crosswalks, CMS did not indicate if it was considering a delay in the May 23 date, after which it has said Medicare "will only accept and send NPI-only transactions," according to the CMS Web site dedicated to NPI implementation.
"This puts providers in an untenable position, and it flies in the face of what the NPI entails," Arges said. It puts providers in a "conflicted position," particularly when they have to deal with payers, such as state Medicaid programs, that want only one NPI to be used.
This latest issue particularly affects hospitals, which have a variety of care units that Medicare often reimburses using different methodologies, such as through diagnosis-related groups, on a cost basis or through some other approach. It's also important on the provider end to know how to reconcile remittances, Arges said.
"Providers would like this to play out with some level of testing (using legacy numbers and NPIs) without penalty," he said. "Unfortunately, this should have been a little more straightforward. The main function for providers is patient care, and it's frustrating and time-consuming when they have to revisit administrative procedures and change things. They don't see any additional value in taking care of patients."