April 2007

CMS clarifies guidelines for NPI deadline

The Centers for Medicare & Medicaid Services (CMS) will implement a contingency plan for covered entities (other than small health plans) who will not meet the May 23, 2007, deadline for compliance with the National Provider Identifier (NPI) regulations under the Health Insurance Portability and Accountability Act (HIPAA) of 1996.

The final rule establishing the NPI as the standard health provider identifier for healthcare providers was published in 2004, and requires all covered entities to be in compliance with its provisions by May 23, except for small health plans, which must be in compliance by May 23, 2008.

The NPI eliminates the current need for multiple identifiers for the same provider. The NPI replaces all “legacy” identifiers currently being used, such as Medicaid provider IDs, individual plan provider IDs, UPINs, etc., and will be required for use on healthcare claims and other HIPAA transactions.

CMS made the decision to provide guidance on its enforcement approach after it became apparent that many covered entities would not be able to fully comply with the NPI standard by the deadline. This guidance will protect covered entities from enforcement action if they continue to act in good faith to come into compliance, as well as develop and implement contingency plans to enable them and their trading partners to continue to move toward compliance.

To apply for an NPI, visit the National Plan/Provider Enumeration System (NPPES) Web site at https://nppes.cms.hhs.gov/.    

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