Home Health & Hospice Week

Don't let CMS contingency plan catch you off guard.

If your to-do list includes managing Medicare's new NPI, get cracking or you could open your business up to enforcement actions and unpaid claims--starting this summer.

A number of dates will be vital to National Provider Identifier use and compliance, said Centers for Medicare & Medicaid Services officials speaking at a May 10 Special Open Door Forum on CMS' NPI contingency plan.

Background: In April, CMS announced that it would extend the NPI deadline for a year, in light of covered entities' lack of readiness (see Eli's HCW, Vol. XVI, No. 12). The contingency plan begins May 23 and is in effect until May 22, 2008--but that doesn't mean you can stop worrying about the new identifier.

Starting point: Providers should have NPIs by now, said a CMS official speaking at the forum. If you don't have an NPI, get one "immediately," urged CMS officials. To do so, go to www.nppes.cms.hhs.gov.

Those who have an NPI should begin testing the new identifier right away, CMS recommends.

Providers not in full compliance with the NPI requirement must have a contingency plan by May 23 when the NPI deadline hits, CMS says (see Eli's HCW, Vol. XVI, No. 14).

Steer Clear Of Rejected Claims

Alert: Even with the contingency plan's extensions, CMS may start rejecting claims submitted without an NPI in primary provider fields as early as July 1, officials stressed at the forum.

"As soon as the number of claims submitted with an NPI for primary providers ... is determined sufficient ... Medicare will begin rejecting claims that do not contain an NPI for primary providers," CMS says in April 24 MLN Matters article MM5595.

The primary provider fields are "billing, pay-to and rendering providers," CMS explains.

Paper jam: Providers must use the NPI on both paper and electronic claims. CMS will also treat claims filed using direct data entry and Medicare's free billing software the same as electronic claims for purposes of NPI compliance.

If you file paper claims, be sure you're using the right form. For example, if you use CMS form 1500, be sure you have the new version ...quot; version 805 ...quot; on hand. If you are using the old version, 1290, your claims will be rejected starting July 1.

If you file paper claims using UB-92, your claims will be rejected starting May 22. Beginning May 23, replace the UB-92 with the new NPI-friendly UB-04.

Remember: The contingency plan spelled out in CMS' April 24 Change Request 5595 applies only to Medicare fee for service. You may soon have other dates and requirements to keep in mind as other health plans release contingency plans of their own.

Providers should look for contingency plan information "from various health plans they bill and with whom they conduct any HIPAA transaction," said a CMS official speaking at the forum. That includes CMS' other health plans, such as Medicare Advantage, Medicare Part D and state Medicaid plans.

Stay Tuned For NPI List

CMS punted yet again regarding the agency's ability to link providers with the NPIs of referring physicians and other providers as necessary.

Officials speaking at the forum announced early in the call that they wouldn't address questions relating to the data dissemination plan, saying the agency would release additional information as soon as possible. Once a plan is in place, CMS will hold another Special Open Door Forum to answer providers' questions about how to access the information.

Providers have until May 2008 to include referring docs' new numbers. Until then, providers can include "secondary" providers' legacy numbers, including UPINs, on Medicare claims (see Eli's HCW, Vol. XVI, No. 15).

Until the to-be-announced NPI deadline, providers can include NPIs, legacy numbers or a combination of NPIs and old numbers on their claims, CMS says.