Findings of the National Provider Identifier
Contingency Status Survey
NPI Problems in Process
Would extending the contingency only make matters worse?
The just-completed NPI Contingency Status Survey reveals not only a dire state of unpreparedness to end the contingency on May 23, but also a suite of systemic problems that time simply will not heal. The vexing problems of un-enumerated providers, poorly-considered crosswalks and conflicting payer mandates has left the industry in a state where moving forward may only make matters worse. Many of these problems are simply not visible from the organizational level -- unless you happen to be a provider whose claims have stopped going through. The results of this survey shine a bright light on the gridlock that will certainly result if we stay on our current course, but also point the way to some manageable -- and sensible -- corrective courses of action.
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"We have not been able to get our Medicare claims paid since late October, 2007."
Individual Provider
"...four month delay in payment because my NPI was not crosswalking."
Professional Provider
"...EDI support staffs at the payers don’t understand the problem... and give the wrong answers to the providers."
Health IT Vendor
"Too few providers have sent NPI only to ensure a successful implementation... there isn't enough time to get to them all to ensure there will be no disruption in payments."
Medicare Plan
click for more quotes... |
Providers Without Number - Why unenumerated providers will always be with us, and how both the regulations and the standards allow us to proceed, despite current regulatory misguidance
- Subparting Schema - How Medicare and other payers have ignored a key provision of the law, and what the consequences might be for all
- Taxonomy Gridlocks - How conflicting taxonomy requirements are causing more trouble than they should
- Pharmaceutical Solutions - The first victims may be patients standing at the counter, holding empty bottles
- Corrective steps for policy and implementation
This Business Intelligence Pack™ includes:
- 106-page report: "NPI Problems in Process"
- In-depth analysis of responses from:
- Medical Providers
- Institutional Providers and Billers
- Professional Providers and Billers
- Health Plans
- Medicare Contractors
and Intermediaries
- Medicaid Plans
- Non-CMS Health Plans
(Commercial, Other Government)
- Pharmacies
- PBMs
- Clearinghouses
- Comments by respondent type
- Public Summary report in PDF
- Full de-identified data set in XLS format
Unique Buy-one/Send-one offer: HITTG will send a copy of the full report and analysis to the trading partner of your choice. On receipt of your order, we will contact you for a name, email address, and any message you might want to pass along. If you prefer, we will be delighted to send to a CMS insider from among our own contacts.
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Click to request the de-identified
source data |
$995 |
$595 |
Free |
An HITTG Business Intelligence Pack:
- Report: "NPI Problems in Process" - 106 pages, 32 charts and tables
- In-depth analysis of responses from:
- Medical Providers
- Institutional Providers and Billers
- Professional Providers and Billers
- Health Plans
- Medicare Contractors and Intermediaries
- Medicaid Plans
- Non-CMS Health Plans (Commercial and Other Government)
- Pharmacies
- PBMs
- Clearinghouses
- Comments by respondent type
- Features and Appendices:
- Thirty+ charts, graphs and tables
- NPI resource links
- Public Summary report PDF
- Full de-identified data set in XLS format
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NPI: Facts in Evidence (55-minute DVD)
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NPI: Medicare Insights (55-minute DVD)
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NPI: Final Status - Results of the NPI Contingency Status Survey (50-minute DVD)
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Live resource links on CD-ROM
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About the National Provider Identifier Contingency Status Survey
Conducted in April, 2008
Rationale for the NPI Contingency Status Survey |
 Why Survey NPI Now? Some Medicare providers have had payments put on indefinite hold, thanks to the implicit complexities of implementing the National Provider Identifier, plus some additional hindrances caused by actions of CMS (see provider quotes at this link).
Payment delays began in October of 2007, but only for a “small” number of claims, according to CMS spokespersons. But the changes planned for the final push to end NPI contingency suggest that number of claims may grow substantially after May 23. The changes include:
- Removing legacy IDs (OSCAR, PIN, UPIN, Medicaid IDs, BCBS Numbers, etc.) from Billing, Pay-to and Rendering provider loops
- Mandating NPIs for all covered entity providers who might appear on the claim (what Medicare refers to as “Secondary Providers” – Referring, Ordering, Operating, Attending, etc.)
– and eliminating legacy IDs for these entities as well
- Mandating NPIs for secondary providers who are not Covered Entities – many of whom do not have NPIs and may actively resist enumerating (for instance, dentists, mental health professionals, retired physicians and others who do not transmit electronic transactions)
- Mandating NPIs for the identification of providers who may have little or no contact with the provider who originated the service (retail pharmacies, DME suppliers, reference labs, etc.)
How big are these problems? This survey was designed to tell us – and the industry.
Will CMS Again Extend the Contingency Period?
We were concerned that yet another enforcement delay, or “re-contingency,” may be of little help, and the survey data agree. The problems appear largely to be in Medicare’s computer code, not the regulatory code of the NPI Final Rule. To the extent that other payers mimic Medicare’s approach, the problems may multiply, even if the fear of enforcement were removed entirely.
What Will the Survey Tell Us? The survey was designed to get a snapshot of what is really happening now – not what plans are in the works or what dates are on the calendar. We did not ask for forward-looking statements. Respondents were not asked to indicate whether they “expect to be compliant” with the law as of May 23, 2008.
The survey was designed to collect numbers and to identify specific problems – or their absence. Many of the questions addressed the specific problems we have identified as key challenges (ending "dual use," secondary providers, un-enumerated providers, etc.).
The survey provided different sequences of questions for providers, payers, clearinghouses and others. Some questions were common to all respondents.
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What questions were asked? |
| Providers were asked how many claims they send per month; the approximate percentage of these that are sent electronically; with legacy ID only (such as OSCAR, UPIN, Medicaid ID, BCBS number, etc.), with NPI+legacy ID (so-called "dual use"), and with NPI only (if any). We also asked specifically about whether a significant number of claims have been held up or denied due to NPI-related problems. Separate sections were provided for different types of claims (Institutional, Professional, Dental, and Pharmacy).
Payers were asked about volumes of incoming claims that fall into specific categories (Legacy-only, NPI+Legacy, NPI-only). Also about crosswalking strategies (to match NPI-only transactions to existing provider records), responses to NPI errors, and payment issues. We urged responses from all segments of the payer community; results were de-identified. PBMs were also included in the questionnaire design.
Clearinghouses were asked about overall claims volumes by type (837I, 837P, 837D, NCPDP). Breakdowns include proportion of direct connections (Provider-CH-Payer) vs. indirect connections (Provider-CH-CH-Payer, etc.) specific NPI problems that occur with direct and indirect submissions and "primary" vs. "secondary" providers.
Billing Services saw questions for the provider commmunities they serve.
All Respondents (including those not specified above) were asked about NPI lookup and other data sources, specific concerns about moving forward, and any other issues not addressed above.
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Why is HITTG Bearing the Cost of the Survey? |
We are worried about the industry. We care about patients and providers, and the many payers who help them pay for services. There is no charge for the raw survey data, but we do hope you will consider purchasing the full report. Visit our research and analysis products page where you'll find our numerous other presentations and publications, many of them free to the industry.
Engage HITTG for healthcare IT consulting, private research projects and other healthcare information technology services. Contact us here. |
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Keywords: Medicare Fee for Service (FFS) National Provider Identifier (NPI) Implementation Contingency Plan primary provider secondary provider HIR #632 NPI National Provider Identifier 837 PRV 837 x12 DISA CMS crosswalk CR4023 CR4320 HIPAA MM4023 MM4254 MM4320 MM5229 MM5243 NPPES R1024CP R1054CP R815CP R983CP edi 837 legacy identifier medicare requirements claim data dissemination final rule iv&v remediation implementation subpart provider crosswalk enumeration online seminar webinar training health information technlogy Medicare NPPES NPI registry NPI lookup privacy
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