CMS Tells Health Care Providers How To Obtain National

MAY 16, 2005
CMS Tells Health Care Providers How To Obtain National
Provider Identifiers For HIPAA Standard Transactions
In this HIPAA Law Alert, we discuss the Centers for Medicare and Medicaid Services’
(“CMS”) recent announcement of the process for health care providers to obtain their
National Provider Identifiers (“NPI”) for HIPAA standard transactions.
What are National Provider Identifiers?
HIPAA required the Department of Health and Human Services (“HHS”) to adopt a
standard unique health identifier for health care providers. On January 23, 2004, HHS
published its Final Rule on National Provider Identifiers, which requires all Covered Entities
under HIPAA to begin using NPIs. In a nutshell, an NPI is a unique identifying number for
every health care provider and it replaces health care provider identifiers that are in use today
in HIPAA standard transactions. NPIs will eliminate the need for health care providers to
use different identification numbers to identify themselves when conducting HIPAA
standard transactions with multiple health plans.
A health care provider’s NPI will be the same for all Medicare and non-Medicare HIPAA
standard transactions. Obtaining the NPI does not, however, replace enrollment or
credentialing procedures with any health plan, including Medicare.
Who Must Use An NPI?
All health care providers -- individuals (such as physicians, dentists, and pharmacists) and
organizations (such as hospitals, nursing homes, pharmacies, and group practices) -- are
eligible to apply for and receive an NPI.
All health care providers who transmit health information electronically in connection with
any of the HIPAA standard transactions are required by the NPI Final Rule to obtain NPIs
(45 CFR Part 162 published in 69 Fed. Reg. 3434 on January 23, 2004). This requirement
applies even if a business associate (such as a billing agency) is used to prepare the
transactions.
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Medicare, Medicaid, all private health plans and all health care clearinghouses must accept
and use NPIs for all HIPAA standard transactions by the compliance date of May 23, 2007.
(Small health plans have one extra year to comply.) However, these entities may require use
of the NPI sooner. Each health plan, including Medicare, will notify health care providers
when they are ready to begin accepting NPIs in standard transactions, such as claims
submissions. The NPI will replace other identification numbers. Only the NPI will be used
after the compliance date in standard transactions.
How Can You Obtain An NPI?
There are three ways health care providers can obtain an NPI:
1. Through a Web-based application process.
The Web address will be
https://nppes.cms.hhs.gov.
The Web–based application will be available
beginning May 23, 2005.
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If all of the information filed using the Web-based application (such as Social
Security number and employer EIN) is complete and accurate, CMS says that
the NPI will be issued within minutes.
2. Use a paper application. However, paper applications may not be submitted until
July 1, 2005.
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CMS says that it cannot estimate the amount of time it will take to obtain an
NPI through the paper application process since the time it will take to issue
numbers will depend on workload and other factors.
3. An organization (such as a professional association or the health care provider’s
employer) with the health care provider’s permission, will be able to submit the
application in an electronic file for several health care providers at once. This
process will be available in the fall of 2005.
Where Can You Get More Information?
CMS has issued a Medlearn Matters memorandum (Number: SE0528) that is available at
http://www.cms.hhs.gov/medlearn/matters/mmarticles/2005/SE0528. pdf
The Medlearn Matters memorandum refers readers for additional information to the
following resources:
•
http://www.cms.hhs.gov/hipaa/hipaa2
•
Beginning May 23, 2005, by visiting https://nppes.cms.hhs.gov or calling the
Enumerator at 1-800-465-3203 / TTY 1-800-692-2326.
•
And, for HIPAA information, by calling the HIPAA Hotline: 1-866-282-0659,
or e-mailing AskHIPAA@cms.hhs.gov
Nixon Peabody attorneys continue to be on the cutting edge of these and other HIPAA
issues. If you have any questions about the Security Rule or HIPAA compliance, please
contact any of the members of our Nixon Peabody HIPAA Task Force or your regular
contact at the firm.
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