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Pathology/Lab Coding Alert

Reader Questions:

Watch for Timely NPI Compliance

Published on Fri May 25, 2007

Question: Do pathologists need to have a National Provider Identifier by May 23 and use it for transactions between providers to comply with HIPAA law?

Ohio Subscriber  Answer: No, you no longer have to meet the May 23, 2007, deadline for national provider identifier (NPI) implementation. Now you-ll have an extra year to get up to snuff on NPI compliance, according to a recent CMS release.
 
The problem: CMS has promised a -data dissemination notice,- but to date it has not provided the instruction. Without any CMS policy, providers didn't know how to obtain the NPIs of doctors who referred patients to them.
 
The solution: That doesn't mean you should halt your progress toward using valid NPI numbers to transmit medical information. CMS hasn't actually suspended the original May 2007 compliance date. Rather, the agency says it will have a relaxed enforcement regime until May 2008. CMS will focus on -obtaining voluntary compliance- and will enforce the NPI requirement only in response to complaints.
 
If CMS receives a complaint before May 2008 that you haven't implemented NPIs yet, CMS will notify you in writing. Then you have a chance to show that you-re in compliance, document your -good faith efforts- to comply, or submit a corrective action plan. CMS will look at NPI compliance on a case-by-case basis.
 
CMS will judge your -contingency plan- based on whether you-ve increased external testing with -trading partners- and whether your providers have actually obtained NPIs.
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