Warning! Uncertain Protection Under NPI Contingency Plan!
To: PSA Affiliated Practices
From: John Outlaw, PSA Chief Compliance Officer
The Centers for Medicare & Medicaid Services (CMS) has recently announced that it is implementing 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 HIPAA. According to the contingency plan, for some period of time after May 23, 2007, Medicare will continue to allow the use of the old "legacy” provider numbers, while at the same time beginning to accept the new NPI. Exactly how long Medicare will continue to allow the use of the old “legacy” numbers depends on their own assessment of the provider community’s readiness, but they have stated that they could begin denying claims that do not include NPIs as early as July or August. In addition, Medicare will permit rendering, or “primary”, providers who are required to identify another provider, such as a referring physician, as part of its Medicare claims submission to continue to use the “legacy” number to identify those “secondary” providers through May 23, 2008.
PSA has worked diligently over the past year to obtain NPIs for all of our billing clients, and we have been testing and filing claims with these NPIs since October 2006. However, even though Medicare has agreed to extend the requirement to provide NPIs for referring or “secondary” providers through May, 2008, this does not prevent other payors which may be ready for NPI from delaying or denying payment for claims submitted without NPIs, and the possibility still exists that YOU MAY NOT RECEIVE PAYMENT for claims filed to some commercial payors after May 23, 2007, without the NPIs for your referring physicians.
Therefore, PSA strongly encourages you to continue being diligent in obtaining referring physician NPIs by the original May 23, 2007 deadline, as coverage under each health plan can not be guaranteed!
Again, the Medicare implementation date for submittal of claims with NPIs is May 23, 2007, and there is no guarantee of protection that will cover your practice and prevent disruption in your cash flow, unless you are able to provide NPIs for all of your referral sources.