Health Information Compliance Alert

Published on Mon Mar 10, 2008 PDF

Are you ready for the May 23 deadline?

When March 1 passed, many practices thought they were free of NPI deadline hassles. Think again.

Most healthcare practitioners know by now that if they didn't have a National Provider Identifier as of March 1, their claims will be denied on sight. But Medicare claims are subject to a separate deadline for referrals, and that date is coming up soon.

Starting May 23, Medicare will deny "referred or ordered services or items" that fail to list the name and NPI of the ordering or referring provider. And it will reject claims that include legacy numbers -- they must be NPI-only.

MLN Matters article 5890 reminds providers of the "requirement to place the 'furnishing' provider or supplier's name and NPI in the appropriate fields."

Remember: Even if the referring provider doesn't participate in the Medicare program, you must still list his or her name and NPI on the claim.

"If you have trouble getting someone's NPI, you can't just leave that box blank," says Heather Corcoran with CGH Billing. "The new MLN Matters article says that you have to put your own name and NPI in the claim's ordering/referring field if you have tried to get the referring doc's NPI but still can't get it."

The Centers for Medicare & Medicaid Services gave providers that work-around for when they just can't obtain NPIs from their referring docs in Jan. 18 Transmittal No. 235 (CR 5890).

Don't forget: Your intermediary or carrier won't automatically enter your information in the referring provider's field if you forget. You have to do it yourself.

Suggestion: "We created a prompt that will come up for the first few months on our claims software," says Jay Neal, a consultant in Atlanta. "When the software opens, a box will come up that says, 'Did you remember your referral field?' We process a lot of claims that require this information, so for us, it will be a huge help to have that reminder."

Resource: You can search the National Plan and Provider Enumeration System (NPPES) database (https://nppes.cms.hhs.gov/NPPES/NPIRegistryHome.do) to find a provider's NPI number if the provider won't give it to you.

The database includes real-time NPPES information. That means you'll have quick access to Freedom of Information Act (FOIA) disclosable data for newly enumerated providers, as well as updates and changes to enumerated providers' FOIA-disclosable data as soon as it's available in the NPPES system.

Note: The memo is at http://www.cms.hhs.gov/transmittals/downloads/R235PI.pdf. The MLN Matters article is at http://www.cms.hhs.gov/MLNMattersArticles/downloads/MM5890.pdf.