RE: NPI - National Provider Identifier (USA) --AMA and other info

[Guest guest]

If anyone's interested, here are selections from

the AMA and Phoenix Health Systems/HIPPAAdvisory

websites. I've added some emphasis in bold type,

and a couple of explanatory comments in [bracketts].

 

3 summary points:

 

1) note the usages of " covered entities " ,

" required " , " elligible/free to " , " compliance not

required " , " media " and " transmission " (in the AMA

material called " transactions " )

 

2) Implementation

a) phased: providers not in Federal Plans, and

not using electronic transmission " will be

enumerated after all other providers. "

b) Implementation will be difficult -- lots of

new human system pieces and computer code; that

means trouble for early adapters. Most problems

will probably relate to the new identifiers, as

that's wholly new processes and code, but also

likely problems with legacy identifiers (our old

SSN or Fed Tax Ids), as processes and code will

be at least partially modified here also. (From

my 30+ years experience in hightech/software

(prior/overlapping with CM education), I know

well how early adapters are turn out to be " debuggers " .)

 

3) the AMA structure and depth of information

about HIPPA and NPI is impressive. A google

search on " acupuncture HIPPA " , as well as

scanning websites of CSOMA (California assn),

AOMAlliance, and AAOM yielded precious little on

HIPPA/NPI information. Perhaps AAOM, CSOMA should

provide a link to the AMA site.

 

This topic's, for me, sufficiently beaten to

death. After this latest information, I

personally will probably hold out applying, and

watch further, monitor other's experiences with

the " implementation " issues. Come to think of it,

a downright useful service for the " professional

associations " might be to set up some group to

just observe and gather information as to how

this will be proceeding, and develop tips and

warnings or solutions to problems as they arise.

And, (just once more) try to give us complete

information and options, not just exhortations to jump on the bandwagon.

 

 

 

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Through the AMA (American Medical Association) website to:

 

http://www.ama-assn.org/ama/pub/category/4234.html

 

" The Health Insurance Portability and

Accountability Act of 1996 (HIPAA) prompted new

Federal regulations which require physicians to

ensure they are protecting the privacy and

security of patients' medical information and

using a standard format when submitting

electronic transactions, such as submitting claims to payers. "

 

Link to " National Provider Identifiers "

http://www.ama-assn.org/ama/pub/category/14479.html

 

Then to " NPI Primer " (MS-Word file named: NPI_Final.doc)

 

" While all physicians who transmit health

information in electronic form are covered

entities and are required to obtain and use a

NPI, non-covered entity physicians (i.e.,

physicians using only paper claims) are also free

to obtain and use a number. Obtaining a number

will not result in making a non-covered entity a covered entity. "

 

 

" How to 'HIPPA' - Top 10 Tips " (I didn't trace

how I found this via links, but this URL gets there)

http://www.ama-assn.org/ama1/pub/upload/mm/435/hipaa10tips-opt.pdf

 

See flow-chart on page 3 on who's required to comply

 

 

Link from (AMA) " " National Provider Identifiers "

page through link " HIPPAAdvisory "

(to a site by Phoenix Health Systems)

http://www.hipaadvisory.com/regs/finalprovid/def.htm

 

Quotes HIPPA regulations:

 

" The varying needs for healthcare provider

numbers guided our decisions on which entities

would be eligible to receive NPIs. Our general

rule is that all healthcare providers, as we

define that term in the regulations, will be

eligible to receive NPIs. We discuss this in detail later in this section.

 

It is important to note that not all healthcare

providers who are eligible to receive NPIs will

necessarily be required to comply with the HIPAA

regulations. This is because some healthcare

providers are not covered entities under HIPAA.

The fact that a healthcare provider obtains an

NPI does not impose covered entity status on that

healthcare provider. Only those entities that (1)

meet the definition of healthcare provider at §

160.103, and (2) transmit health information in

electronic form on their own behalf, or that use

a business associate to transmit health

information in electronic form on their behalf,

in connection with a transaction for which the

Secretary has adopted a standard (a covered

transaction) are healthcare providers who are

required to comply with the HIPAA regulations. "

 

http://www.hipaadvisory.com/regs/natlident.htm

 

Who and What Are Covered?

 

Section 1173 of HIPAA Administrative

Simplification called for “a standard unique

health identifier for each individual, employer,

health plan, and health care provider for use in

the healthcare system.” The Act recognized that

DHHS would have “to take into account multiple

uses for identifiers and multiple locations and

specialty classifications for healthcare

providers.” The proposed rules apply to health

plans and clearinghouses, and any provider

electronically transmitting any of the

transactions covered by HIPAA. As a practical

matter, software vendors that have contracts with

health plans and providers to support healthcare

transactions will also be affected by the identifier requirements.

 

“Electronic transmissions” includes all media,

including magnetic tape, disk, CD media, the

Internet, extranets, leased lines, dial-up lines,

and private networks. Telephone voice response,

" faxback " systems, and HTML interaction are not

included. Transmissions within a corporate entity are not affected.

 

[NOTE: memory media such as disk here means not

those used as local or network internal storage

systems, but as transmission media, i.e.

physically moved from one computer/network to another.]

 

....

 

 

How Will We Implement the NPI?

 

DHHS has recommended that the NPI be implemented

through a central electronic National Provider

System (NPS), to be managed by HCFA. The NPS will

consist of a combination of existing Federal

health plans, Medicaid state agencies and a new,

Federally-directed registry -- all of whom will

assign identifiers, or “enumerate” providers.

Federal health plans and Medicaid agencies will

enumerate their own healthcare providers.

Providers who don’t belong to one of the included

Federal programs will be enumerated by the Federally-directed registry.

 

NPI enumeration will be implemented in phases.

First, providers that submit electronic Medicare

transactions will automatically be assigned an

NPI. Non-Medicare health plans such as Medicaid

and HMOs will then phase in enumeration of their

providers. Providers using these programs will

not need to apply for an NPI, but will have to

decide which health plan will provide it.

Providers who do not participate in any Federal

health plans or Medicaid but who transmit

standard HIPAA transactions electronically, will

have to apply directly to the new Federal

registry for their NPIs. Finally, providers who

don’t participate in any Federal plans or

transmit the electronic transactions covered by

HIPAA are expected to be enumerated after all

other providers. The NPS will maintain the national database in perpetuity.

 

[NOTE: So in the final phase of implementation,

all other providers, presumably including

non-covered entities, will be " enumerated " .]

 

Implementation of the NPI is likely to be a

challenge, both for the Federal government and

the healthcare community. The proposed National

Provider System does not yet exist, and while

enlisting the participation of Federal plans may

help lower set-up costs, coordinating an initial

nation-wide enumeration process and managing the

transition from multiple identifiers to a single

identifier environment may become complicated.

Providers and other organizations will have to

update their legacy information systems,

administrative processes, reference files and

forms in order to ensure continuity between old

provider identifiers and the new NPIs. Some

providers and vendors will find that their

systems require tweaking or significant

reengineering to accommodate the new standard.

Health plans, clearinghouses and software vendors

may have to perform software conversions to meet the requirement.

 

[NOTE: Conversion to the use of NPI will likely

result in numerous mistakes and problems,

probably more for those using the new numbers, as

that computer code will be new, but likely also

for those still using legacy ids, such as SSN or

Fed Tax Id, as old computer code will be messed

with also. General guideline (from my 30+ years

in a former career in computer tech): early

adapters had better have a high tolerance for problems and frustration!]