Retraction: FAQ 5816 Found

I couldn't handle it. I hate leaving uncited references in my blog posts. I finally dug around through my own materials and found some text I had copied from CMS FAQ 5816 back in 2006 -- the one I referenced in today's earlier blog.

I was wrong -- so wrong -- that 5816 said you couldn't use non-NPI identifiers in NCPDP pharmacy transactions. Here it is, plain as day:

If a covered entity needs to identify a noncovered health care provider who does not have an NPI in a standard transaction, the noncovered health care provider:

• Must be identified by its SSN or EIN as its Primary Identifier in standard transactions designed to capture a Primary and a Secondary Identifier for a health care provider….
• Must be identified by one of the qualifiers (other than the qualifier for the NPI) listed in the Implementation Guides for the standard transactions that are designed to capture a single identifier for a health care provider.

Geez, talk about having egg on my face. There they were, telling the entire industry exactly how to accommodate for the unenumerated provider, and I thought they hadn't accounted for exceptions.

You Never Hear the One That Gets You
That's in bullet two, by the way. I remember, now, because I had to ask whether the second bullet was for all those X12 transactions that allow you to send just a secondary ID (like a UPIN, a Medicaid ID, a BCBS number, etc.) if no primary ID is available. They said no, silly, that's about the NCPDP transaction, where there is only one provider ID segment available. Bullet one is for X12; Bullet two is for NCPDP.

I completely forgot about that email.

My Bad
So I guess I should take all that stuff back about CMS not allowing for reality. On the X12 transactions, just send the Social Security Number if you don't have the NPI. Unless it's illegal. Or, of course, if the doctor who won't obtain an NPI won't give you his SSN either.

Or, unless you're billing Medicare, which, it turns out didn't read CMS FAQ 5816 when they said to send your own NPI in place of the Referring, Attending, Ordering, etc., when he/she/it didn't have an NPI. Wrong again, Marty!

Or, wait, now that they took 5816 down, I guess we can't assume that it's okay to do that, either. And I guess the people who built their systems around all the implementation details 5816 contained -- the ones that weren't in the NPI Final Rule or the X12 Implementation Guides -- better get ready to make some changes.

Don't worry. You've got until May 23. Let's keep looking for those new instructions. I'll let you know if I see them first.

Comments

[Darrell Pruitt]

I have one question. Once all of the NPPES magic is in place, and regardless of whether I personally have an NPI or not, can my elderly and handicapped dental patients reliably receive antibiotics within 24 hours of surgery from a local pharmacy as they do now, or should I start stocking my shelves with the medications I commonly prescribe?

That brings up another question. If I charge my patients for the medications I dispense out of my office, will they be reimbursed by their insurance company?

Now that I think about it, there is one more concern, should I self-refer to my storeroom. It’s that pesky Stark Amendment going to cause a bunch of worry?

This isn’t Central America. How hard should it be to provide medicine to patients in a timely and efficient manner? What is CMS thinking? Or should I ask: Who is being served by these capricious rules? I can assure you that it is not the patients I know. Darrell Pruitt DDS