Printable format	E-mail article:	Search news:

By Arlene Furlong

Washington—The U.S. Centers for Medicare & Medicaid Services will not impose monetary penalties on the May 23 deadline for national provider identifier implementation.

CMS April 2 announced an enforcement delay of up to 12 months after it became apparent that many covered entities would not be able to fully comply with the standard.

The NPI is a 10-digit standard identification number for health care providers. Just like other regulations under the Health Insurance Portability and Accountability Act, the NPI applies to all health care providers and provider organizations that transmit HIPAA electronic transactions—either directly or through a vendor or clearinghouse.

The most common HIPAA standard electronic transactions used by dentists are electronic claims and eligibility inquiries. Others include electronic remittance advice and claim status inquiries.

"The enforcement guidance clarifies that covered entities that have been making a good faith effort to comply with the NPI provisions may, for up to 12 months, implement contingency plans that could include accepting legacy provider numbers on HIPAA transactions in order to maintain operations and cash flows," said Leslie V. Norwalk, CMS acting administrator about the April 2 announcement.

Legacy numbers are the identifiers in common use today, such as dental plan-specific identifiers, license numbers and Social Security numbers that plans use to identify health care providers.

Despite the contingency period CMS is allowing for NPI implementation, the ADA is urging all dentists to be NPI ready, including those who don't file HIPAA standard electronic transactions.

"As a precaution against possible delays in claims payments, dentists should be ready," said Dr. Robert Shaw, vice-chair of the Council on Dental Practice.

Under the regulation, the contingency period only applies to HIPAA transactions. Because paper claims are not covered under HIPAA, dental plans have the prerogative to require the NPI as their health provider identifier on paper claims before the 12 months is up. Some payers are already doing this.

"Payers will most likely standardize their claim forms," advised Dr. Shaw. "With the NPI number required for so many providers, it's unreasonable to think payers will retain their legacy numbers for the few who may not be required to have one."

Another possibility dentists should anticipate is that insurers can end their NPI contingency plans for HIPAA electronic standard transactions prior to the 12-month period CMS is allowing. Dental informatics experts say such action is unlikely—because all of a payer's key business partners would have to be NPI compliant at the same time—but not impossible.

"Plans are off the hook for 12 months, but dentists are not if a plan decides to end its contingency plan voluntarily in advance of the deadline," summarized Dr. Shaw. "A worst-case scenario might be claims rejections."

To be ready, dentists have to first obtain an NPI, and then successfully test it with their business partners who will need them to pay benefits or facilitate delivery of health care.

During the initial testing period, some payers may request that dentists submit both their current identifiers and their NPIs, so payers can couple the NPI in the claims system with the legacy identifiers. Dentists who have already begun testing have learned that an incorrectly entered or truncated NPI may not be linked with their current legacy numbers for proper identification and may be returned by payers for correction and resubmission.

Dental informatics specialists believe the NPI may have some advantages over identifiers now in use. Once implemented across the health care industry, the NPI will be accepted by all dental plans as a valid provider identifier. Providers, including dentists, will not have to maintain multiple, arbitrary identifiers required by dental plans, nor remember which number to use with which plan.

Jean Narcisi, director of the ADA Department of Dental Informatics, urges dentists to begin testing their NPIs with payers and business partners.

"The provider identifier is at the heart of the billing and claims payment process for every covered entity," says Ms. Narcisi. "Successful implementation of the NPI and its use in internal systems and external transactions will be important for continued reimbursement."

The 2006 ADA claim form, which supports the use of NPIs, is now available. A sample of the 2006 form with detailed completion instructions is included in chapter four of CDT 2007-2008. In addition, a sample is available on ADA.org at www.ada.org/goto/claimform.

Visit www.ada.org/goto/npi to read the March 5, ADA News article detailing how to apply for an NPI and how to use it on the ADA claim form, as well as additional resources and information from the ADA Department of Dental Informatics and the Centers for Medicare & Medicaid Services.