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Medicaid, Medicare, and NPI Contingency
April 12, 2007

The Department of Public Welfare (DPW) has established contingency guidance in response to the Centers for Medicare and Medicaid Services (CMS) National Provider Identifier (NPI) contingency guidance issued April 2. DPW representatives state that approximately 20 percent of all Medical Assistance (MA) providers have registered. Affected providers are strongly encouraged to obtain NPIs and register them with DPW as soon as possible. Between May 23 and 31, DPW will install new software that will permit use of the NPI. During this period, providers should use only the legacy number. The NPI can be used with the legacy number, but if the NPI is used these claims will be held for one week before being processed on June 1.

Beginning June 1, providers will have the option to use the legacy number, the NPI, or both. The crosswalk is being tested now and should be operational by June 1. However, providers must use both the legacy number and the NPI at the outset to ensure that the crosswalk works for their organization and claims can be paid. After the crosswalk is verified, providers will then be encouraged to use only the NPI. If the crosswalk does not work, providers will be notified by a Remittance Advice Banner Page. Providers will also be notified if the crosswalk links to a different legacy number. Providers are instructed to call the Provider Inquiry Line if the crosswalk between the legacy number and NPI does not match. DPW will soon establish phone contact with individuals rather than voice messaging to answer NPI questions. Beginning May 23, 2008, the NPI will be required and may be used with the legacy number. If only the legacy number is used at that time, the claim will be denied.

DPW reports that there are no delays now in validating NPIs. Representatives stressed that the validation information must be sent to the Office of Medical Assistance Programs, not to the Office of Mental Health and Substance Abuse Services. Also, to complete the process, providers must ensure that the enumeration notification letter is provided to OMAP by fax or mailed copy as explained in Medical Assistance Bulletin 99-06-14, Instructions For Registering Your National Provider Identifier (NPI) Number to the Department of Public Welfare (DPW). If confirmation from the enumerator was provided by email, the email can be forwarded to PROMISe@state.pa.us. PCPA members are requested to contact Betty Simmonds at PCPA if they experience delays in validation of the NPI.

Highmark Medicare Services reports that 82 percent of Medicare providers nationwide have NPIs. Medicare carriers, as covered entities, are waiting for guidance from CMS on what they are to do if Medicare providers are not ready by May 23. Providers are encouraged to use both the legacy number and the NPI to establish a crosswalk, then transition to only the NPI. Feedback from Highmark Medicare Services suggests that all Medicare providers are expected to obtain NPIs by May 23. After May 23 contingency plans are available and allow the use of corrective action plans, but the corrective action is to be completed within 30 days. A CMS NPI Roundtable call on Contingency Plans is scheduled April 18 from 2:30 – 4:00 p.m. and may provide additional clarifications. Registration for this call was closed due to demand. Replay of the call will be available on the CMS web site (www.cms.hhs.gov/NationalProvIdentStand/04_education.asp).

Highmark Medicare Services staff also reported that there are plans to establish an NPI registry in the future. However, a data dissemination rule is needed. This entails publication of a proposed rule in the Federal Register with comment, then publication of a final rule with comments addressed. CMS will not share NPI numbers until such a rule is established. Large organizations may choose to establish their own databases with this information to facilitate operations.

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