The Centers for Medicare & Medicaid Services (CMS) announced the implementation of a contingency plan for covered entities, excluding small health plans, not able to meet the May 23, 2007, deadline for compliance with the National Provider Identifier (NPI) regulations. The regulations are a part of HIPAA. Small health plans have until May 23, 2008 to comply.
The NPI is an identifier that will be used by covered entities to identify healthcare providers, eliminating the current need for multiple identifiers for the same provider. The NPI replaces all legacy identifiers that are currently being used. It will be required for use on healthcare claims and other HIPAA transactions.
“The enforcement guidance released today 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 CMS Acting Administrator Leslie V. Norwalk, Esq.
CMS made the decision after it became apparent that many entities would be unable to fully comply with the NPI standard by May 23, 2007. Entities that are able to show good faith efforts to comply will be protected against enforcement action. They must also develop and implement contingency plans to enable them and their trading partners to continue to move toward compliance, CMS said.
The enforcement process is complaint driven and will allow covered entities to demonstrate “good faith efforts” and employ contingency plans. If a complaint is filed against a covered entity, CMS will evaluate the entity's "good faith efforts" to comply with the standards and would not impose penalties on covered entities that have deployed contingencies to ensure that the smooth flow of payment continues. Each covered entity will determine the specifics of its contingency plan. Contingency plans may not extend beyond May 23, 2008, but entities may elect to end their contingency plans sooner. Medicare will announce its own contingency plan shortly.
For more: https://nppes.cms.hhs.gov/.