Thompson Coburn Health Care Law Alert

HIPAA Update:  CMS Issues New Guidance On Subpart NPIs

Among the many issues addressed in the Health Insurance Portability and Accountability Act of 1996 (HIPAA) is the mandatory use of National Provider Identifiers (NPIs). Beginning May 23, 2007, NPIs must be used by all health care providers that are covered entities under HIPAA (e.g., hospitals, nursing homes, ambulatory surgery centers, physicians) to identify themselves when conducting electronic transactions with third-party payors, including Medicare and Medicaid. This means that as of May 23, 2007, providers may no longer use current identifiers, such as Medicare provider numbers.

Additionally, CMS clarified that a subpart is not a separate legal entity, but rather is a separate business of a health care organization. For example, a health system that owns a hospital, home health agency, long-term care facility, ambulatory surgery center and a physician practice must ensure that an NPI is obtained for each such business. A copy of this CMS guidance can be found at http://www.cms.hhs.gov/NationalProvIdentStand/06_ implementation.asp.

Noncompliance with the NPI rules will result in nonpayment of services. To avoid interruptions in claims payments, providers need to understand the NPI requirements and prepare for the transition. It is important to communicate with your payors early regarding the transition and to apply for NPIs as soon as practicable. Providers may apply for an NPI online or obtain a paper application at https://nppes. cms.hhs.gov.

Additional information about the implementation of NPIs may be found at: http://www.cms.hhs.gov/NationalProvIdentStand/ or by contacting a member of the Thompson Coburn Health Care Group.