CMS communications clarify NPI deadlines, NPPES requirements, and use of SSNs
HIPAA Weekly Advisor, December 3, 2007
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CMS released two Communications in November aiming to clarify several requirements and deadlines in regards to the NPI implementation process.
The CMS Communication dated November 2 reminds healthcare providers of the requirement to update their information in the National Plan and Provider Enumeration System (NPPES). The communication states, "Health care providers who are covered entities under HIPAA are required by the National Provider Identifier (NPI) Final Rule to update their NPPES data. The Final Rule [at (162.410(a)(4)] states that covered health care providers must notify the NPPES of changes in their required NPPES data elements within 30 days of the changes. Failure to provide updated information may be considered an act of non-compliance with the NPI regulation . . ." Providers can make most updates via the Web. However, certain updates require a signed paper form (form CMS-10114).
The November 2 Communication also announces an important update in the NPI implementation timeline. For physicians, other practitioners, providers, and suppliers that bill Medicare carriers, A/B Medicare Administrative Contractors (MACs), and DME MACs using an electronic claim form (ASC X12 837P) or Paper Claim Form (CMS-1500) will now require an NPI in the primary fields on the claim (i.e., the billing, pay-to, and rendering fields) on Medicare fee-for-service claims. CMS says that as long as the NPI is in the primary field, NPI/legacy pairs can continue to be used until further notice. CMS also states that a failure to submit an NPI in the primary fields will result in rejected or returned claims as unprocessable beginning March 1, 2008.
CMS also released a Communication on November 26, reminding providers that they should not report Social Security numbers (SSNs) in NPPES fields that the Freedom of Information Act requires NPPES make publicly available. Because some providers have reported their own SSNs, or the SSNs of other providers, CMS has been suppressing all nine-digit numbers found in disclosed fields (except for fields containing phone numbers or Zip codes).
To read the November 2 and November 26 CMS Communications, click here.
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