The proposed regulation text, in 142.404, stated that health plans would be required to accept and transmit, directly or through a health care clearinghouse, the NPI on all standard transactions wherever required. They would incur implementation costs for converting systems, especially those that generate electronic claims, from current health care provider identifiers to the NPI. The specification for this standard, NCITS.284, is available from the American National Standards Institute, 11 West 42nd Street, New York, New York 10036. will be a repeating field. The level of assignment of NPIs must be adequate to enumerate entities that meet the definition of health care provider at 160.103. This pertains to workforce members within small or large healthcare provider offices, health plans, group health plans, and healthcare clearinghouses. Those electronic applications that are successfully processed (that is, the health care provider is assigned an NPI) will be maintained indefinitely in a manner whereby certification statements can be verified if required. Response: In December 1997, an American National Standard for a Uniform Healthcare Identification Card was approved by the National Committee for Information Technology Standards (NCITS), which is a standards-developing organization accredited by the American National Standards Institute. electronic version on GPOs govinfo.gov. An NPI is inactivated upon death or dissolution of the health care provider. Health plans, excluding small health plans, are required to obtain HPIDs by 2 years after the effective date, in 2014. This situation has become notably problematic in Medicare Part D. The final rule announced today addresses this problem. This is the same as the Employer Identification Number (EIN) used on an organization's federal IRS Form W-2. The majority of atypical and nontraditional service providers are not considered health care providers and, therefore, would not be eligible for NPIs. Comment: Some commenters expressed concern that the professional claim or equivalent encounter information transaction be able to accommodate address or location information associated with billing, pay-to, and furnishing health care providers. Because they were aware that the NPI was an upcoming standard, they may have also made some accommodations in their systems to be able to use the NPI when it is assigned. Comment: Many commenters stated that all health care providers should be able to obtain NPIs, whether they conduct health care transactions electronically or on paper. Small health plans must do so within 36 months of the effective date. We note that the initial five digits 80840 would be required with the NPI only when the NPI is used as a card issuer identifier on a standard health care identification card. We estimate the following costs for operations of the National Provider System (NPS), keeping in mind that the NPS will enumerate both covered and noncovered health care providers, and that health care providers are not being charged for obtaining NPIs. In manipulating and reformatting the files, problems could be discovered in some of the health care provider records that would require investigation and resolution. This fact could explain why health plans sometimes have a greater percentage of updates than what we estimated for NPI purposes in the proposed rule, and could have been the basis on which the comment was made. In complying with the requirements of part C of title XI, the Secretary established interdepartmental implementation teams who consulted with appropriate State and Federal agencies and private organizations. We are including this listing to show readers the kind of information that we expect will be collected about health care providers or that will be NPS-generated (for example, the NPI) about health care providers. The large number of members of some groups and the frequent moves of individuals among groups would make national maintenance of group membership burdensome and expensive. In addition to the description of the NPI standard, this section of the May 7, 1998, proposed rule discussed several other points on which we received comments: We noted that we proposed the 8-position alphanumeric format rather than a longer numeric-only format in order to keep the identifier as short as possible while providing for an identifier pool that would serve the industry's needs for a long time. Its development cannot be finalized until publication of this final rule. Secs. There will still be costs and savings related to the implementation of the NPI by health plans and health care providers. A durable medical equipment supplier chain, for example, has a corporate headquarters and separate physical locations at which durable medical equipment is dispensed to patients. NPIs may be used to identify health care providers in patient medical records. c. security. Response: The data element table in this preamble includes an indication of required, optional, or situational for each data element, and repeating data elements are noted as such. Commenters cautioned that any data to be loaded into the NPS should be validated, accurate, and up to date. Thus, this final rule does not include billing services and similar entities as health care providers. The location code would not uniquely identify an address; different health care providers practicing at the same address would have different location codes for that address, resulting in complexity, rather than simplification, for business offices that maintain data for large numbers of health care providers. Examples of hospital components include outpatient departments, surgical centers, psychiatric units, and laboratories. Each health care provider must obtain, by application if necessary, an NPI. The codes may reflect UPIN, NSC, OSCAR, DEA, Medicaid State or PIN identification numbers. 2, Definition of Health Care Provider in this preamble, most of them do not meet our definition of health care provider. The most significant benefit of the HPID and the OEID is that they will increase standardization within the HIPAA standard transactions. The National Provider System (NPS) will be a large, complex system. We agree that the NPS record will be based on the data described in Alternative 2. In the May 7, 1998, proposed rule, we presented two alternatives for the structure of health care provider data in the NPS. If it has been assigned NPIs for one or more subparts, comply with the above requirements with respect to each of those NPIs. These factors make a single enumerator the more efficient option. HIPAA required that HHS adopt a national plan identifier, with the intent of improving the utility of HIPAA transactions and . Paper applications will be maintained indefinitely for signature or certification statement verification and audit purposes. We have included the statements to address the anticipated effects of this final rule under section 202 of UMRA. The mailing address and one practice address (physical location) will be collected by the NPS for each health care provider. Because of complexities that are inherent in disseminating data from the NPS, it is necessary to eliminate from the NPS Data Elements Table the column that, in the proposed rule, indicated the data dissemination level. If the NPS encounters problems in processing the application, appropriate messages will be communicated to the applicant. It may not be used in any activity otherwise prohibited by law. Communicate to the NPS any changes to its required data elements in the NPS within 30 days of the change. Comment: Several commenters suggested adding Cross reference to replacement NPI. They thought it would be important to link former and current NPIs. For example, it was assumed that all of the HIPAA standards would be issued and effective at about the same time, so that covered entities would be making their system changes at one time. A more detailed analysis of the impact on small businesses is part of the impact analysis that we published on August 17, 2000 (65 FR 50312), for all the HIPAA standards. Health care providers may use other health care providers NPIs to identify those other health care providers in health care transactions and on related correspondence. The number of health care providers needing to update their data in any year is a percentage of the number of health care providers. We could not solicit comments on the effect of Executive Order 13132 on the adoption of the health care provider identifier standard. Once licensed as an allopathic or osteopathic physician, the physician should update his/her data in the National Plan and Provider Enumeration System (NPPES) by submitting a change in the Healthcare Provider Taxonomy Code to reflect the change in status from medical student to physician. These transactions might request all available data, regional data, new records only, and updated records only. We find that seeking public comment on and delaying the effective date of this correcting amendment would be contrary to the public interest. Response: The May 7, 1998, proposed rule at 142.408(c) proposed 60 days to allow reasonable flexibility in the time required for a health care provider to complete a paper form (the NPI application/update form) containing the update(s) and forward it to the NPS. This process involves reviewing and validating a Start Printed Page 3447paper application containing far more information than will be collected and validated on the NPI application/update form. Comment: Several commenters suggested that we publish a data model and record layout or both describing in detail the data elements, field lengths, format, repeating fields, and required and situational fields. Therefore, because these kinds of entities are not health care providers, they will not be eligible for NPIs. 264 of Pub. 4 = other (for example, retirement), The date that the provider's NPI was deactivated in the NPS, Required if NPI deactivation code contains data, The date that the provider's NPI was reactivated in the NPS, The date of birth of the individual being identified, The code representing the State in which the individual being identified was born. One entity will be given enumeration functions under the direction of HHS (option 1 as presented in the May 7, 1998, proposed rule) to enumerate all eligible health care providers who apply for NPIs. (See section II. Comment: Several commenters suggested that a number of other data elements be excluded from the NPS: all user-requested data elements (these were denoted by a U in the data element list in the May 7, 1998, proposed rule), Other provider number, Other provider number type, Organization type control code, Provider certification code, Provider certification (certificate) number, Provider license number, Provider license State, School code, School name, School city, State, country, School graduation year, Provider classification, Date of birth, all electronic mail addresses and fax numbers, Date of death, Provider sex, and Resident/Intern code.. Because the compliance dates cover such an extended period of time, we will estimate part of the overall cost and savings for health plans and health care providers that can be attributed to the NPI. We estimate that, on the effective date of the NPI, approximately 2.3 million health care providers will be ready to apply for NPIs. Some health care providers would incur those costs directly and others would incur them in the form of fee increases from billing associates and health care clearinghouses. Covered health care providers must disclose their NPIs to other entities that need those health care providers' NPIs for use in standard transactions. The unique identifiers under HIPAA regulations are: Standard Unique Employer Identifier (EIN) This is the same as the Employer Identification Number (EIN) used on an organization's federal IRS Form W-2. Commenters who favored a broad definition of health care provider recognized the many business functions and uses in health care transactions fulfilled by health care provider numbers today. A new NPI will not be required when there is a change in an organization health care provider's name, Employer Identification Number, address, Healthcare Provider Taxonomy classification, State of licensure, or State license number. The project participants decided to develop a new identifier for health care providers because existing identifiers did not meet the criteria for national standards. Each health care provider must accept and transmit NPIs whenever required on all standard transactions it accepts or transmits electronically. While every effort has been made to ensure that A covered health care provider must comply with the implementation specifications in 162.410 no later than May 23, 2007. Under the Security Rule, covered entities, regardless of their size, are required, under 164.312(a)(2)(i) to assign a unique name and/or number for identifying and tracking user identity. A user is defined in 164.304 as a person or entity with authorized access. Accordingly, the Security Rule requires covered entities to assign a unique name and/or number to each employee or workforce member who uses a system that maintains electronic protected health information (e-PHI), so that system access and activity can be identified and tracked by user. (Catalog of Federal Domestic Assistance Program No. In this regard, we encourage all health care providers to obtain NPIs and, when requested, to disclose their NPIs to covered entities that need them for inclusion on health care transactions.
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