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CMS announces NPI contingency period

Physician Practice Advisor, April 4, 2007

The Centers for Medicare & Medicaid Services (CMS) will not enforce the May 23 deadline for national provider identifier (NPI) implementation, as long as covered entities "demonstrate good faith efforts and employ contingency plans," the agency announced April 2.

The enforcement delay allows the industry to continue using legacy numbers on claims as part of contingency plans to ensure payment. Contingency plans may not extend past May 23, 2008. The agency also announced that Medicare will soon release its own contingency plan for use of the new identifier.

"CMS will focus on obtaining voluntary compliance and use a complaint-driven approach for enforcement," the agency said in its guidance. "CMS will not impose penalties on covered entities that deploy contingency plans (in order to ensure the smooth flow of payments) if they have made reasonable and diligent efforts to become compliant."

CMS will provide written notice to the covered entity of any complaints it receives. The entity will then have the opportunity to do one of the following:

  • Demonstrate compliance with the NPI standards
  • Document its good faith efforts to comply with the NPI standards
  • Submit a corrective action plan