Medicare FFS NPI Implementation Contingency Plan

Medicare fee for service (FFS) announces that it is establishing a contingency plan that follows the DHHS guidance. Medicare FFS will evaluate the number of submitted claims containing a NPI. If this analysis demonstrates a sufficient number of submitted claims contain a NPI, Medicare will begin to reject claims without NPIs on July 01, 2007. If, however, there are not sufficient claims containing NPIs in the May analysis, Medicare FFS will assess compliance in June 2007 and determine whether to begin rejecting claims in August 2007.

For some period after May 23, 2007, Medicare FFS will:

• Allow continued use of legacy numbers on transactions
• Accept transactions with only NPIs
• Accept transactions with both legacy numbers and NPIs

After May 23, 2008, legacy numbers will NOT be permitted on ANY inbound or outbound transactions.

CR 5595 also provides specific important information that you should be aware of:

• Once a decision is made to require NPIs on claims, Medicare FFS will notify (in advance) providers and Medicare contractors about the date that claims without NPIs for primary providers will begin to be rejected. That date will supersede all dates announced in previous CRs and MLN Matters articles.
• In editing NPIs, Medicare considers billing, pay-to and rendering providers to be primary providers who must be identified by NPIs, or the claims will be rejected once the decision is made to reject.
• All other providers (including referring, ordering, supervising, facility, care plan oversight, purchase service, attending, operating and Ã’otherÓ providers) are considered to be secondary providers. Legacy numbers are acceptable for secondary providers until May 23, 2008. If a secondary providerÕs NPI is present, it will only be edited to assure it is a valid NPI.