The teams also received comments on the May 7, 1998, proposed regulation from a variety of organizations, including State Medicaid agencies and other Federal agencies. Most commenters supported the collection of credential designation(s) (for example, M.D., C.S.W., and R.N. Comment: One commenter stated that the costs for option 1 as shown in Table 5 did not reflect the savings that would have accrued by preloading Medicare provider files into the NPS. The first two years would have increases of 36,124 and 37,251 in new covered health care providers, respectively. If a billing service needs to be identified as the Billing provider, it would identify itself with either an Employer Identification Number (EIN) or a Social Security Number (SSN). The Congress included provisions to address the need for a standard unique health identifier for health care providers and other health care system needs in the Administrative Simplification provisions of HIPAA. Data in addition to those which are published in the Unique Physician Identification Number (UPIN) Directory should not be released. Covered entities may also use statistical methods to establish de-identification instead of removing all 18 identifiers. This is the same as the Employer Identification Number (EIN) used on an organization's federal IRS Form W-2. As mentioned earlier in this preamble, HHS will contract for system development and for the enumeration, update, and data dissemination activities. Comment: Some commenters expressed concern that the professional claim or equivalent encounter information transaction be able to accommodate address or location information associated with billing, pay-to, and furnishing health care providers. Practice type control information is not required to uniquely identify or classify a health care provider for NPS purposes; therefore, it will not be included in the NPS. endstream endobj 147 0 obj <. (Note: No health care provider is required to have an NPI before 2007.) This principle supports the regulatory goals of cost-effectiveness and avoidance of burden. As explained in the May 7, 1998, proposed rule (at 63 FR 25323), the implementation teams charged with designating standards under the statute defined, with significant input from the health care industry, a set of common criteria for evaluating potential standards. HIPAA for Professionals | HHS.gov One commenter, who had suggested the enumerator be a public and private sector trust, suggested that dissemination fees be established and administered by the public and private sector trust. Response: The DEA number is an example of an Other provider identifier. The DEA number can be accommodated in this field in the NPS. Cost considerations also contributed to our decision. One possible alternative in the development of the identifier was to allow intelligence to be included in it. NOTE: The abbreviation NA means not applicable.. We also ordinarily provide a delay of 30 days in the effective date of the final rule. If the health care provider is similar (but not identical) to an already-enumerated health care provider, the situation will be investigated. Many of these components or separate physical locations are separately certified or licensed by States as health care providers. Many health care providers that are organizations (such as hospitals and chains of suppliers of health care-related supplies, pharmacies, and others) are made up of components or separate physical locations. (Requests for Privacy Act-protected data and Freedom of Information Act (FOIA) requests would be handled in accordance with existing HHS policies.). At this time, bulk enumeration of health care providers is not expected to occur. The HIPAA Unique Identifiers Rule. When an organization health care provider is disbanded, the organization health care provider's NPI will be deactivated. The final rule, CMS-0040-F, may be viewed at www.ofr.gov/inspection.aspx. A. Organization health care providers that are chains generally have a corporate headquarters and a number of separate physical locations. Below are the questions as posed in the May 7, 1998, proposed rule followed by a summary of the comments and our responses: Responding yes: Some commenters stated that they need to capture the multiple practice addresses of a health care provider for their business functions. Any inconsistencies or errors that are present in health care provider files that are considered to be used to populate the NPS would be imported into the NPS as part of that process. National Provider Identifier (NPI) The Secretary would be able to extend the time for compliance with any modification by small health plans by rulemaking, if he determines that an extension is appropriate. Situational (S): If a certain condition exists, the data element is required. Comment: Some commenters said that License revoked indicator and License revoked date should be included in the NPS. Faulkner & Gray lists 78 physician practice management vendors and suppliers, 76 hospital information systems vendors and suppliers, 140 software vendors and suppliers for claims-related transactions, and 20 translation vendors (now known as Interface Engines/Integration Tools). Statutes and regulations also authorize or require other Federal agencies, including the Departments of Agriculture, Commerce, Education, Housing and Urban Development, and Labor, to collect EINs in connection with administering various Federal programs and laws. Some commenters stated that health care providers that do not conduct any of the transactions named in HIPAA should be able to obtain NPIs. Below we respond to the comments received about that part of the impact analysis. This is because some health care providers are not covered entities under HIPAA. In complying with the requirements of part C of title XI, the Secretary established interdepartmental implementation teams who consulted with appropriate State and Federal agencies and private organizations. The figures in Table 2 have been adjusted to reflect dollars expressed for 2007. The extended effective date of the NPI should allow sufficient time for health plans, health care clearinghouses, and health care providers who are covered entities to implement the changes needed to accommodate the NPI. Health care providers may use their own NPIs to identify themselves in nonstandard health care transactions and on related correspondence. We published the final rule, entitled Health Insurance Reform: Standards for Electronic Transactions (the Transactions Rule), on August 17, 2000 (65 FR 50312). Response: We respond to these issues as follows: Medicare Part B carriers indicated in comments that it costs about $50 to enroll a health care provider in the Medicare program. Comment: We received many comments concerning the length of time a health care provider should be allowed before it must notify the NPS of changes to its NPS data. Respondents noted several technical weaknesses of the proposed location code. If feasible, we will populate the NPS with Medicare provider files. Those issues relate to applicability, definitions, general effective dates, new and revised standards, and the aggregate impact analysis. The NPS will contain a date (Last update date) that will indicate when a change was made to a health care provider's record. Some commenters pointed out that Federal and Medicaid health plans do not maintain all of the information about health care providers that would be required to assign NPIs; thus, if those health plans' prevalidated health care provider files were to be used to populate the NPS, costs might exceed $50 per health care provider in order to obtain the missing information needed to assign NPIs. This commenter recommended that the public and others obtain NPIs from the health care providers themselves, not from the NPS. Federal funds will support the enumeration process and the NPS, at least initially. We are adopting the NPI format of an all-numeric identifier, 10 positions in length, with an ISO standard check-digit in the 10th position (162.406(a)). of this preamble, NPS Data Structures, contains the comments and responses and decisions made regarding NPS data structures. In particular, they work with health care providers' practice management and health information systems. If they do not electronically transmit any health data in connection with a transaction for which the Secretary of Health and Human Services has adopted a standard, they are not covered health care providers under HIPAA and are not required by the NPI Final Rule to obtain NPIs. A new NPI will not be required for change of ownership, change from partnership to corporation, or change in the State where an organization health care provider is incorporated; indeed, ownership and incorporation information will not be contained in the NPS. This analysis required that we use data and statistics about various entities that operate in the health data information industry. The Privacy Rule The HIPAA Privacy Rule regulates the use and disclosure of Protected Health Information (PHI) held by covered entities, and protects individuals' rights to understand and control how their health information is used. Since that time, pharmacies have encountered situations where the NPI of a prescribing health care provider needs to be included in the pharmacy claim, but the prescribing health care provider does not have an NPI or has not disclosed it. Additional examples are health maintenance organizations that may be considered health care providers as well as health plans if they also provide health care. Comment: Many commenters suggested that several data elements be repeated; for example: Provider's other name and Provider's other name type; Other provider number and Other provider number type; Provider license number and Provider license State; Provider classification; the data elements associated with schools; and the data elements associated with credentials. Covered entities have 180 days from the final regulations effective date to comply with the additional NPI requirement. Security standards are to be implemented by April 2005, and the NPI must be used by 2007. They did not believe it would be accurately reported. Lastly, HIPAA gives small health plans an extra year (36 months instead of 24 months from the effective date) in which to implement the NPI. of the preamble should be kept in mind in reading this section. A few other commenters recommended a 9-position numeric identifier. The NPS will apply changes or updates to the Other provider identifier or Other provider identifier type code when health care providers notify the NPS of changes to this information. In addition, the limited validation by the NPS of data reported by health care providers will further reduce NPS costs. Based on the assumption that the burden associated with systems modifications that need to be made to implement the NPI may overlap with the systems modifications needed to implement other HIPAA standards, and the fact that the NPI will replace the use of multiple identifiers, resulting in a reduction of burden, commenters should take into consideration when drafting comments that: (1) One or more of these current identifiers may not be used; (2) systems modifications may be performed in an aggregate manner during the course of routine business; and/or (3) systems modifications may be made by contractors such as practice management vendors, in a single effort for a multitude of affected entities. Examples of hospital components include outpatient departments, surgical centers, psychiatric units, and laboratories. Medical insurance chapter 4 Flashcards | Quizlet Obtaining NPIs and disclosing them to entities so they can be used by those entities in standard transactions will greatly enhance the efficiency of health care transactions throughout the health care industry. For example, it was assumed that all of the HIPAA standards would be issued and effective at about the same time, so that covered entities would be making their system changes at one time. Response: We have not seen documentation that would convince us our estimate was incorrect at the time the May 7, 1998, proposed rule was published. Have low additional development and implementation costs relative to the benefits of using the standard. (5) If it uses one or more business associates to conduct standard transactions on its behalf, require its business associate(s) to use its NPI and other NPIs appropriately as required by the transactions that the business associate(s) conducts on its behalf. For more information, visit the CMS website at: National Provider Identifier Standard (NPI). The selection of the NPI does not impose a greater burden on the industry than the nonselected candidates. Some commenters asked if on-line access charges would be based on time or on a per file access basis. L. 104-191, which was enacted on August 21, 1996, required the adoption and use of a standard unique identifier for health care providers, CMS and the other project participants accepted the NPI as the standard unique health identifier for health care providers. The level of assignment of NPIs must be adequate to enumerate entities that meet the definition of health care provider at 160.103. Health plans, health care clearinghouses, and health care providers who are covered entities must use NPIs in standard transactions and must make the necessary changes and conversions in order to do so. Health care providers and subparts, as appropriate, will apply for NPIs. Under this final rule, health care providers will not be charged a fee to be assigned NPIs or to update their NPS data. To sign up for updates or to access your subscriber preferences, please enter your contact information below. Do I need a National Provider Identifier (NPI) as well? We have added to the NPS two new data elements: National Provider Identifier deactivation reason code and National Provider Identifier deactivation date. These data elements will capture the information suggested by this commenter. The May 7, 1998, proposed rule also stated that phase three would not begin until phases one and two were completed. Within the comment and response portion of this final rule, for purposes of continuity, however, we use the term requirement when we are referring specifically to matters from the proposed rule. These credential designations will not be verified by NPS, The first line mailing address of the provider being identified. The costs of investigating and resolving these problems were not recognized earlier and, therefore, were not considered in the May 7, 1998, proposed rule. A health care provider who is a covered entity under (HIPAA is required to obtain an NPI, and to use that NPI to identify itself as a health care provider in HIPAA standard transactions. Groups will be enumerated as organization health care providers. The fees would represent their proportion of the total health benefit dollars; the trust organization would administer various databases required by the HIPAA standards (not solely the NPS). We believe these timeframes enable more than sufficient time for covered health care providers to become aware of their responsibilities under this final rule, to apply for and be assigned their NPIs, and to complete work needed to begin using their NPIs. Response: The NPI application forms will contain a statement whereby the signer attests to the accuracy of the information on the application. (2) Applying for an NPI is a one-time burden on a health care provider. (4) Communicate to the NPS any changes in its required data elements in the NPS within 30 days of the change. Therefore, we will attempt to design a form that can serve both application and update purposes. Specifically, we codified the definition of health care provider at 45 CFR 160.103. Keep data collection and paperwork burdens on users as low as is feasible. We believe the mapping capability and naming convention compatibility are essentially what the commenters wanted and believe we have satisfied their concerns. Examples of health care provider organizations with an Entity type code of 2 are: hospitals; home health agencies; clinics; nursing homes; residential treatment centers; laboratories; ambulance companies; group practices; health maintenance organizations; suppliers of durable medical equipment, supplies related to health care, prosthetics, and orthotics; and pharmacies. A durable medical equipment supplier chain, for example, has a corporate headquarters and separate physical locations at which durable medical equipment is dispensed to patients. Description of the information contained in each column of this table: Data Element Name: The name of the data element residing in the NPS. The purpose of part C is to improve the Medicare and Medicaid programs in particular, and the efficiency and effectiveness of the health care system in general, by encouraging the development of a health information system through the establishment of standards and implementation specifications to facilitate the electronic transmission of certain health information. The NPI format would allow for the creation of approximately 20 billion unique identifiers. Health plans may use NPIs in their internal health care provider files to process transactions and in communications with health care providers. A. Response: No commenter suggested that different data be collected for a group practice than for an organization health care provider and a strong majority of commenters stated that the same data should be collected. Official websites use .govA Covered entities (except for small health plans) must begin using the NPI in standard transactions no later than 24 months after the effective date. Comment: Several commenters stated that the NPS should be required to apply updates within a specified period of time after receipt of the updated information from a health care provider. For purposes of this rule, we consider group health care providers to be organization health care providers. The .gov means its official. Over ten years, the projected net savings of implementing HPID for the entire health care industry is approximately $1.3 billion to $6 billion. A paper form (the NPI application/update form) will be developed for this same purpose and will be available from the NPS and from the CMS Web site (http://www.cms.hhs.gov) for use by health care providers. The Start Printed Page 3446NPS will uniquely identify and enumerate health care providers at the national level. They indicated that any errors present in those files would be carried undetected into the NPS. It is true that some health plans may have to maintainfor internal purposesdual health care provider numbers: the NPI and the number(s) issued to health care providers by the health plans themselves. They stated that the format of the location code would allow for a lifetime maximum of 900 location codes per health care provider, and this number may not be adequate for health care providers with many locations. The NPS will contain as many repeating fields as there is information for Provider other last or other organization name and Provider other last or other organization name type code. As mentioned earlier, the NPS will also be able to accommodate multiples of other health care provider numbers in the data element Other provider identifier and types of other health care provider numbers in the data element Other provider identifier type code. The NPS will accommodate multiple entries for Provider license number and Provider license State. As explained earlier, the school information will be excluded from the NPS. ), license number(s), and State(s), which issued the license(s) for individual health care providers whose taxonomy classifications require licenses. All covered health care providers are eligible for NPIs and may apply for them. The penalties for nonuse of a single standard and nonuse of multiple standards should be clarified. A health care provider that is a covered entity must obtain, by application if necessary, an NPI from the NPS. The HPID is assigned by the Health Plan and Other Entity Enumeration System (HPOES) to all health plans. We asked how the NPS could be designed to make it useful, efficient, and low-cost. These criteria also support and are consistent with the principles of the Paperwork Reduction Act of 1995. Some software vendors also provide applications that translate information on paper and information in electronic records having no standard formats into standard electronic formats that are acceptable to health plans. Response: The May 7, 1998, proposed rule at 142.408(c) proposed 60 days to allow reasonable flexibility in the time required for a health care provider to complete a paper form (the NPI application/update form) containing the update(s) and forward it to the NPS. Optional (O): Not required for NPI assignment. B. A health care provider may choose not to report a former name or a professional name. Response: In the proposed rule, the NPS was proposed to include many data elements that we have since decided not to include. The prescriber may be a physician or other practitioner who does not conduct standard transactions. This final rule will have a substantial effect on State and local governments to the extent that those entities are covered entities. Responding no: A large majority of commenters noted that health care provider membership in groups changes frequently and that this information will be burdensome and expensive to maintain and will be unlikely to be maintained accurately at the national level. The National Provider Identifier (NPI) is a unique identification number for covered health care providers. We estimate that, on the effective date of the NPI, the number of health care providers that typically do not conduct standard transactions will be approximately 3.7 million. Response: The design of the NPS will facilitate making information available in an efficient manner, which will involve the use of the Internet. Secs. Comment: Some commenters asked that we clarify how the NPI would appear when used as a card issuer identifier on a standard health care identification card. that agencies use to create their documents. Disclose its NPI, when requested, to any entity that needs the NPI to identify that health care provider in a standard transaction. While the purpose of this extended effective date is to allow HHS sufficient time for NPS development and testing, it will also permit health care entities sufficient time to accommodate changes needed in order to implement the NPI. Secs. Many commenters who favored a narrow definition of health care provider want to simplify the current situation for health care providers; that is, a health care provider may have many health care provider numbers assigned by health plans for different business functions. Commenters recommended that agreements be signed by anyone receiving NPS data to ensure the. or This final rule establishes a Federal private sector mandate and is a significant regulatory action within the meaning of section 202 of UMRA. HIPAA requires the Secretary to adopt standards that have been developed, adopted, or modified by a standard setting organization, unless there is no such standard, or unless a different standard would substantially reduce administrative costs. Small health plans are required to obtain HPIDs 3 years after the effective date, in 2015. Once an NPI is assigned, the health care provider will be notified of its NPI. We encourage health care providers who have been assigned NPIs but who are not covered entities also to notify the NPS of changes in their NPS data within 30 days of the changes. Of the 78 claims clearinghouses listed in this publication, eight processed more than 20 million electronic transactions per month. If considered feasible, the affected health care providers will be notified and will not have to apply for NPIs. If the NPS encounters problems in processing the application, appropriate messages will be communicated to the applicant. A data element, the Entity type code, in the NPS record for each health care provider will indicate the appropriate category. d. Should the NPS Collect the Same Data for Organization and Group Health Care Providers? An official website of the United States government. The format of the NPI (all numeric) will facilitate telephone keypad entry; the check-digit in the 10th position will detect keying and data entry errors; and the lack of intelligence built into the NPI will eliminate the need to issue a new health care provider number (and maintain records of such issuances) whenever changes occur that would impact that intelligence. Federal Register. Another commenter stated that health plans will use the health care provider's mailing address as the pay-to address. A. HHS adopts a standard for a HPID, a data element that will serve as an OEID, and an addition to the NPI requirements. In the latter case, and in the case of the subpart described above, an NPI would not be available for use in the standard transaction. b. The NPI may also be used on paper claims, but HIPAA does not govern that method of submitting paper claims. The May 7, 1998, proposed rule (at 63 FR 25328) described our proposal for the standard health care provider identifier. These can be useful National Provider Identifier Standard (NPI) | CMS Responding yes: A large majority of commenters stated that a distinction between organization and group health care providers would be artificial and would serve no purpose.
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