Medicare Compliance & Reimbursement

Providers breathe a little easier with 1-year NPI extension.

Good news: You'll have an extra year to get up to snuff with your national provider identifier (NPI) compliance.
 
With less than two months left before crunch time, the Centers for Medicare & Medicaid Services (CMS) decided to give you until May 23, 2008, to become NPI-only with all your transactions. If you're not quite ready by May 23, 2007, you can implement a "contingency plan" to maintain your cash flow, CMS said in a release.

Why the change? CMS tried to make it sound as if providers weren't ready for the original deadline. But CMS was also behind on its obligations, noted the Medical Group Management Association (MGMA). CMS failed to issue a policy that would "facilitate the communication of NPIs," said MGMA president and CEO William Jessee in a release.

Without any CMS policy, providers didn't know how to obtain the NPIs of doctors who referred patients to them. The MGMA has posed a sample letter to request a referring doctor's NPI on its site at www.mgma.com, but CMS has been promising a "Data Dissemination Notice" on NPI-sharing for years now.

The lack of this CMS policy has "hindered industry efforts to meet the original compliance date," MGMA said.

To come: CMS promises it will soon make data available to help you develop "crosswalks" between old provider numbers and NPIs.

Meanwhile, CMS hasn't actually suspended the original May 2007 compliance date. Rather, the agency says it will have a relaxed enforcement regime until May 2008. CMS will focus on "obtaining voluntary compliance" and will enforce the NPI requirement only in response to complaints.

If CMS receives a complaint before May 2008 that you haven't implemented NPIs yet, CMS will notify you in writing. Then you have a chance to show that you're in compliance, document your "good faith efforts" to comply or submit a corrective action plan. CMS will look at NPI compliance on a case-by-case basis.

CMS will judge your "contingency plan" based on whether you've increased external testing with "trading partners," and whether your providers have actually obtained NPIs.