Medicare is, as predicted, moving forward to make National Provider Identifier (NPI) processing part of the real world of claim submission.
Effective March 1, 2008, Medicare fee-for-service 837P and CMS-1500 claims must include an NPI in the primary fields on the claim (i.e., the billing, pay-to, and rendering fields). You may continue to submit NPI/legacy pairs in these fields or submit only your NPI on the claim. You may not submit claims containing only a legacy identifier in the primary fields. Failure to submit an NPI in the primary fields will result in your claim being rejected or returned as unprocessable beginning March 1, 2008. Until further notice, you may continue to include legacy identifiers only for the secondary fields. [MLN Matters MM5749 (Revised)]
Looking Out for Number 1
Meanwhile, it seems the regulatory arm of CMS still can't figure out how to determine whether an entity is a person or an organization and thus continues to hold back tax ID numbers submitted by Type 2 providers, for fear they might actually be the Social Security Numbers of Type 1 providers. Why does that matter? Well, for one, the only way to ensure you have picked up the right NPI for a particular subpart of an organization is to get a cross reference generated by that organization's Tax ID.
Without that, expect lots of misdirections as "St. Alphonso Dialysis" and "St. Alphonso's Kidney Center" and "Red State Nephrology - St. Alphonso Campus" will not show up on any single list, any other way.
This is Going to Hurt You A Whole Lot More Than It Hurts Your Brother
I'm even more concerned about what happens with the real challenge -- sorting out mandates for non-affiliated secondary providers -- hits the fan on May 23. That's this May 23. If Medicare follows through on this new/improved drop-dead date, expect other payers to try to hold the line, too.
In spite of the fact that many secondary providers don't have an NPI, aren't required to get an NPI and have actively refused to obtain one. But if they show up on your claim, you might not get paid.
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