The Centers for Medicare & Medicaid Services (CMS) announced today a contingency plan that extends the compliance date for the National Provider Identifier (NPI) to May 23, 2008 for covered entities that will not meet the May 23, 2007 deadline, but whom are making a “good faith effort” to do so.
You can read the full press release here: CMS Press Release on NPI Contingency Plan.
Basically, CMS is saying that they now realize that many covered entities will not be able to fully comply with the NPI standard by the May 23, 2007 deadline. So they will not take any enforcement action on non-compliant entities if they can show CMS they are making a “good faith effort” to comply with the standards. Some of the examples of good faith efforts include:
- For a health care provider, having obtained an NPI and having the ability to use it on HIPAA transactions.
- For a health plan, concerted efforts in advance of the May 23, 2007 deadline and continued efforts afterwards to conduct outreach and make testing opportunities available to its provider community.
- For other “trading partners”, increased external testing with other trading partners.
We don’t think you can interpret this announcement as a blanket extension of the NPI deadline. Instead, we think CMS is basically saying, hey, let’s not kid ourselves, not everyone is ready for full NPI compliance and we need to give organizations a backup plan who are genuinely doing their best to implement the NPI standard.
We recommend Kareo customers continue at full throttle on their NPI transition. We are ready for NPI today. You can enter NPI numbers for practices, providers, service locations, and referring physicians in Kareo. You can print out the new CMS 1500 form with NPI support. And just a few weeks ago, we started sending NPIs in all outbound electronic claims. So we recommend you take advantage of Kareo’s NPI support and make every effort to comply with the original May 23, 2007 deadline.
For more information about the National Provider Identifier (NPI) standards, please visit the Centers for Medicare & Medicaid Services NPI resources page at: http://www.cms.hhs.gov/NationalProvIdentStand/.