Health Information Management

CMS clarifies NPI implementation

HIPAA Weekly Advisor, November 5, 2007

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CMS clarified a few points regarding the upcoming NPI implementation process, according to an October 24 Communication.

The Communication discusses the following:

  • Reasons as to why residents at teaching hospitals and academic medical centers should obtain an NPI.
  • Information for Medicare providers concerning NPI implementation dates. CMS notes that it "has not yet announced the date by which an NPI will be required for primary provider fields on 837 professional electronic claims and 1500 paper claims processed by carriers, A/B MACs and DME MACs. This will occur prior to May 23, 2008; a specific date will be announced once available."
  • Information for Medicare providers on common claims problems and errors that cause rejections.
  • Information clarifying the NPI Requirement on Medicare Institutional Claims for January 1, 2008. CMS states the following, "effective 1/1/08, NPIs will be required to identify the primary providers (the Billing and Pay-to Providers) in Medicare electronic and paper institutional claims (i.e. 837I and UB-04 claims). You may continue to use the legacy identifier in these fields as long as you also use the NPI in these fields. This means that 837I and UB-04 claims with only legacy identifiers in the Billing and Pay-to Provider fields will be rejected starting on 1/1/08." CMS also states, "You may continue to use only legacy identifiers for the secondary provider fields in the 837I and UB-04 claims, until 5/23/08, if you choose."
  • Suggestions for claims submitters as to how to test for rejections, including sending a small number of claims using NPIs only (no legacy identifiers).

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