Frequently Asked Questions
Q: What is the CMS guidance on NPI contingency?A: On April 2, 2007, CMS released NPI guidance to allow contingency plans to be implemented by covered entities making a good faith effort to comply with the NPI provisions. These contingency plans may include acceptance of legacy provider numbers on HIPAA transactions. Contingency plans may not extend beyond May 23, 2008, but covered entities may elect to end their contingency plans sooner.
This is not an extension but a non penalty phase. The enforcement guidance applies to all covered entities (providers, plans, clearinghouses) and to all aspects of NPI.
Information on the April 2, 2007 contingency plan announcement is available at: http://www.cms.hhs.gov/NationalProvIdentStand/Downloads/NPI_Contingency.pdf
Q: What is Humana’s plan for NPI after 5/23/2007?
A: Humana has elected to continue with the dual identifier strategy beyond May 23, 3007. The dual identifier strategy means the ability to exchange transactions using any of the following:
NPI only, Legacy identifier (Humana specific ID) + NPI, or the Legacy Identifier only
Providers who are using only their tax ID (with or without NPI) and are not making any changes to your existing billing processes should not experience any issues.
In preparation of enforcing the NPI mandate, Humana will routinely evaluate the rate of NPI adoption on transactions to determine if there are a sufficient number of NPI only transactions to justify enforcement prior to the May 23, 2008 date
Q: Does CMS’ announcement regarding contingency plans mean that providers have an additional 12 months to obtain and begin using NPIs?
A: No, Humana strongly encourages providers to begin submitting their NPI on electronic transactions as soon as possible. By submitting electronic claims to Humana, your NPI is then collected into our claim systems. Any health care provider or organization defined as a covered entity under HIPAA is required to obtain an NPI. Providers who transmit health care information via HIPAA standard electronic transactions are covered entities under HIPAA, whether they transmit the transactions themselves or use a vendor to transmit them.
Failure to obtain an NPI prior to May 23, 2007 may be viewed by CMS as a violation of the good faith provisions of the contingency/enforcement guidance
Q: What is Humana’s policy on disclosing another provider’s NPI?
A: On May 30, 2007, CMS published the rule on disclosing NPIs in the Federal Register. In summary, access to a provider’s NPI will be free of charge through the internet. Access to this information can be through a file download or by query only. Humana concurs with this approach and will redirect providers wanting NPI access to the address that will be further defined by CMS. For more information go to:
http://www.cms.hhs.gov/NationalProvidentStand/
Q: If I do not submit electronic transactions, why do I need an NPI?
A: All HIPAA-standard transactions are impacted by the NPI – not just electronic claims. Also, pharmacy providers will need to access your NPI to process your prescriptions. Some states may require the usage of NPI(s) on paper claim forms, request information from your state Dept of Insurance for this information.
Q: Where can additional information about HIPAA NPI regulations be found?
A: See the CMS website: http://www.cms.hhs.gov/NationalProvIdentStand/
CMS has also consulted with the Workgroup for Electronic Data Interchange (WEDI) in the development of standards and for comments on data dissemination and other issues. WEDI has formed several workgroups consisting of representatives from all areas of the health care industry. See published "white papers" on various topics and other information on the WEDI website: www.wedi.org.
Q: Will Humana require taxonomy codes to be submitted after May 23, 2007
A: Humana will only require taxonomy codes, when a provider is contracted with more than one specialty. If a provider has one NPI and is billing for several specialties, the taxonomy code will help determine for which specialty the provider is billing.
Q: Is Humana currently accepting the updated CMS 1500, the ADA Dental form, and the new UB04 claim forms?
A: Humana is accepting the old HCFA 1500 form and UB92 as well as the new updated CMS 1500 and UB04 at this time. We encourage providers to use the new updated forms with the fields designated for NPI(s).
Q: Which claim form will Humana require after May 23, 2007?
A: Humana currently accepts both the HCFA-1500 and the updated CMS 1500 form. CMS and the NUCC have extended the required date for using the revised 1500 claim form to June 2007. The revised CMS 1500 claim form should be used at this time due to the changes that include the NPI fields. Claims that come to Humana on the older version of the forms will not be rejected.
Q: How do I submit the NPI on a paper HCFA 1500 form or a UB92 form?
A: An updated CMS 1500 form is available. The new form has designated fields for the NPI(s). There is also an updated UB04 form for institutional claims that has replaced the UB92 form. There are fields for the NPI on the UB04.
Q: Where do the NPI(s) need to be input on the new updated claim forms?
A: For information about the fields on the updated claim forms and guidance on the changes, see website: www.nucc.org (The National Uniform Claim Committee website)
Q: Will Humana require the NPI on all paper forms?
A: Humana will not reject any paper claims that do not have the NPI included. The NPI on paper claim forms is not part of the NPI mandate, but it is strongly encouraged. Some states may require the usage of NPI on the paper forms. Providers will want to check with their state Dept of Insurance for their state ruling.
Q: Will I receive my NPI back on my 835 remittance information?
A: Providers need to be sure that if you are sending your NPI to Humana on electronic claims that you have checked with your clearinghouse to ensure that they are ready to receive back the NPI on your 835 remit. Humana will return the NPI on the 835 remit if it is sent in on your 837.
Q: Where can I find more information about HIPPA and NPI standards?
A: For information about NPI, or other HIPAA standards, see the CMS Website: http://questions.cms.hhs.gov. This site provides information related to NPI and other HIPAA standards.
Q: Can a provider or organization have more than one NPI?
A: Yes. The purpose of the NPI is to have only one identifier for individual providers. Some organizations will be required to have subpart identifiers when conditional requirements are satisfied.
Q: Will Humana require the NPI on any non-HIPAA transactions?
A: No. For any non-HIPAA transaction, the NPI will not be required by mandate, but it is recommended.
Q: Can an NPI be deactivated?
A: Yes. However, NPIs are intended to be assigned for life and can be deactivated only under the most extreme circumstances, such as the following:
- Identity theft cases when the provider’s NPI has been used fraudulently
- Provider’s death
- Provider’s retirement
Q: How can I get my individual, group, and or subpart NPIs to Humana?
A: Humana requests that you send your NPI(s) on electronic claims at this time in order for your NPI(s) to be loaded in our systems.
A: Yes. Even though the organization that you are working with has enumerated, you need to obtain an NPI as an individual provider.
Q: What is the mandated usage for NPI?
A: NPI must be the primary identifier in each of the following HIPAA-mandated electronic transactions:
- 837 – Claim Submission, institutional, professional, and dental
- 835 – Remittance Advice
- 270/271 – Eligibility Inquiry and Response
- 276/277 – Claims Status Request and Response
- 278 – Referrals and Response