The Health Insurance Portability and Accountability Act (HIPAA) mandated the adoption and use of a standard identifier called the National Provider Identifier (NPI) for all health care providers to be used in electronic transactions. NPI will be required on paper transactions only in those states where this is mandated, such as Minnesota. This standard identifier will replace the current Medicare identifiers (UPIN and OSCAR numbers) and Health Plan proprietary provider numbers for standard EDI transactions. HIPAA requires that covered entities (i.e., health plans, health care clearinghouses, pharmacies, and health care providers) that transmit any health information in an electronic HIPAA format, use NPI in transactions by the compliance date of May 23, 2007, with a compliance date of May 23. 2008 for small health plans.

On April 2, 2007 the Centers for Medicare & Medicaid Services (CMS) announced that it is implementing a contingency plan for covered entities (other than small health plans) who will not meet the May 23, 2007, deadline for compliance with the National Provider Identifier (NPI) regulations under the Health Insurance Portability and Accountability Act (HIPAA) of 1996. For a 12 month period after the compliance date (i.e., through May 23, 2008), CMS will not impose penalties on covered entities that deploy contingency plans.

Uniprise NPI Update:

• The NPI application period began on May 23, 2005. Click here for more information on the application process from the National Plan and Provider Enumeration System.
• UnitedHealthcare has taken the necessary precautions to ensure that systems are able to “process without disruption” if an electronic claim transaction is received with an NPI prior to the May 23, 2007 compliance date. This means that an NPI is disregarded if received on a transaction and the systems will continue to process the transaction based on the primary identifier.
• UnitedHealthcare began collecting NPI information in January 2006 and is storing it internally.
• UnitedHealthcare will have the ability to download NPI data from the National Provider and Plan System (NPPES) into internal provider databases. This process will be defined upon completion of the CMS “Data Dissemination” notice.
• To assist our trading partners, Uniprise developed companion documents to describe the company-specific details for HIPAA transactions, including the usage of NPI. The Uniprise companion documents contain supplementary instructions for the HIPAA implementation guides. These companion documents do not replace or modify the HIPAA implementation guides, but should be used in conjunction with them (the HIPAA implementation guides can be found at www.wpc-edi.com).
• The National Uniform Claim Committee (NUCC) and the National Uniform Billing Committee (NUBC) have released modified versions of the current professional and facility claim forms. Among the changes will be the inclusion of NPI data fields. The revised claim forms and critical transition and effective dates are:
  • The transition from the CMS 1500 to the 1500 HICF (Health Insurance Claim Form) is October 1, 2006 with a mandatory compliance date of April 1, 2007.
  • The transition from the UB92 to the UB04 Form is from March 1, 2007 with a mandatory compliance date of May 23, 2007.
• UnitedHealthcare has made a business decision to initially accept transactions sent to us without NPI or with incorrect NPI to ensure uninterrupted quality service to our providers and our members.  Furthermore, we will not reject transactions that contain other legacy identifiers in addition to NPI.  We are considering a timeframe in which we will reject transactions that come in without NPI.
• UnitedHealthcare and Its Affiliates are working towards a timeframe in which we will not accept HIPAA transactions that require an NPI, but are received without an NPI or with an invalid NPI. The goal is to be in full-compliance on or before May 23, 2008. Any changes to our current policy for accepting transactions without NPI will be preceded with communications to physicians, health care professionals, organizations and trading partners regarding when we expect to begin to not accept HIPAA transactions that do not contain a valid NPI in the fields specified by the Implementation Guide.  Refer to the UnitedHealthcare and Its Affiliates NPI Contingency Plan below:
  
  UnitedHealthcare NPI Policy for Trading Partners (.doc file)
  
  UnitedHealthcare and Its Affiliates NPI Contingency Plan (.pdf file)

Related Links:

Centers for Medicare & Medicaid Services FAQs

CMS News for Medicare Fee for Service Providers