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Guidance On The National Provider Identifier Contingency

The Centers for Medicare and Medicaid Services (CMS) recently announced a degree of leniency in the NPI final deadline of May 23rd, 2007. This contingency plan for the NPI implementation states that if covered entities (other than small health plans) show indications of good faith (progression towards NPI compliance) after the compliance date of May 23, 2007, CMS will not impose penalties.
Leniency was granted because medical transactions require the participation of two entities, each of whom is required to participate in the NPI process. Non-compliance by one party may result in difficulty of another party to declare full NPI compliance. Additionally, the NPI compliance deadline for small health plans is not until May 23, 2008, which creates additional compliance issues for medical professionals that work with these entities.

CMS states that if medical entities are making ‘good faith’ strides to implement NPI numbers they will grant leniency. ‘Good faith’ contingencies may include:
• Increased external testing with trading partners.
• Lack of availability of, or refusal by, the trading partner(s) prior to May 23,2007 for health plans (other than small health plans) to test the transaction(s) with the covered entity whose compliance is at issue.
• In the case of such a health plan, concerted efforts in advance of the May 23, 2007 and continued efforts afterwards to conduct outreach and make testing opportunities available to its provider community.
• For a health care provider, having obtained an NPI and having the ability to use it on HIPAA transactions.

Whether you’ve had your NPI number for months or are applying for it, AdvancedMD software is NPI compliant and ready to accept the new system at any time. Use both your existing (legacy) number and the NPI number when submitting electronic claims and test transactions with those entities. If you're an client there is no need to stress about compliancy with new regulations and initiatives, we’re always ready.

Apply for your NPI number as soon as possible. Visit the official NPI registration site for details.

By: AdvancedMD

11 April 2007

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