NPI Survey: Can We Assess Readiness Before It's Too Late?

The industry seems to be sliding obliviously into yet another regulatory deadline: The NPI Contingency period officially expires May 23. Which means what, exactly?

Let me tell you what it doesn't mean, in my humble and entirely non-legal opinion:

• It doesn't mean that the HIPAA Police are going to suddenly rush out of the donut shop and start issuing fines or slapping the cuffs on doctors or CEOs.
• It doesn't mean that Medicare or most any other payer is suddenly going to mandate a level of compliance that three years of remediation hasn't created in the test bed, much less in the real world. (Well, Medicare might.)

Before You Put Your Head Back Under the Sand
Unfortunately, it doesn't mean you're off the hook either.  If you're a provider, you could easily become the next victim of a payer crosswalk failure, like the ones that are leaving certain Medicare billers unpaid for months. If you're a payer, you may be drawn deeper into the vortex of inconsistent and unjustifiable interpretations of the NPI Final Rule that your industry peers may be applying -- not via provider newsletters, but via hard-coded edits -- some of which may make it impossible for certain providers to satisfy your own requirements.

So, before CMS issues yet another clarification of what May 23 really means, let me suggest a mantra that will help you get through the months ahead: It's not about compliance, it's about revenue. Ignorance may or may not be an excuse, but it's pretty hard to cash at most banks.

It Could Be Raining
How bad is it? We have our suspicions, but nobody knows. People at CMS, of course, probably know a lot more about how bad it is inside Medicare than they're letting on, but nobody really knows how it's impacting providers, other payers and the clearinghouses that connect them.

How Fast Can HITTG Do A Survey?
That's why we decided, early last week, to do a survey to find out how bad it is (or isn't).  We dropped all our other wonderful priorities and hammered out a pretty impressive instrument, if we do say so.  It focuses on what is really happening, not on what folks "plan" to do. It focuses on some particular problems we've seen emerge and go unresolved for months (years, actually). Things like providers who don't have NPIs, payer crosswalks that don't close all the gaps, and a general unwillingness to appreciate the fact that the NPI regs and standards are designed to get providers out of the business of meeting arbitrary, inconsistent and undocumented payer identification requirements.

SECRET INDUSTRY TIP: Providers are not responsible for routing claims around inside the walls of health plans.

Is it too late? We really don't think so.  Here's why:

• NPI problems will not go away on May 23, with or without a "re-contingency" notification from Medicare.
• The problems we are seeing will cause a dramatic spike in payment disruptions, if current plans are carried forward. If we are correct, the survey results will help prove it. If we are wrong, the survey results will disprove it and we can move on to something else.
• Payers may acknowledge only a "few" problems, but if you are one of the providers affected, those few can include, quite literally, 100% of your payments from that payer.
• Policymakers and remediators do not seem to be suffering from an excess of useful information.

It's Fast, It's Free, It's Frightening
That's why we're doing the survey. That's why we have such a short timeframe (collection ends on Saturday, April 19). That's why we're releasing the results to anyone who asks, within days, not weeks or months. That's why we're putting together short, low-cost webinars [link] to help people make it through May 23 and beyond.

Please take the survey. And please help us spread the word.

Comments

[Darrell Pruitt]

What the healthcare industry needs now is more open communication. Thanks, Martin. Darrell Pruitt DDS