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NPI Survey Predicts Gridlock

The full report includes dozens of charts, graphs and tables -- enough ammo to rock the most uncooperative trading partner -- and all the regulatory citations to back you up.

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The full report includes dozens of charts, graphs and tables -- enough ammo to rock the most uncooperative trading partner -- and all the regulatory citations to back you up.
A survey of U.S. healthcare providers, health plans and other key players indicates that May 23, the last day of the one-year contingency for National Provider Identifier (NPI) implementation, may bring about widespread claims disruptions. Many healthcare providers are concerned about weeks or months of cash flow crisis as hundreds of millions of dollars in claims payments are delayed.

The survey provides a detailed look at facts-on-the-ground from various points of view. Institutional providers report almost 98% of their claims are going out with their own NPIs, but a full 82% of those also include their legacy ID to assist payers with proper matching and payment – a precaution that Medicare and other health plans vow they will not allow after the deadline. Another key concern is how billers will represent those practitioners – who may refer patients, order lab tests and write prescriptions – but who may have chosen not to obtain an NPI. This may be their right under certain regulatory exceptions, but will disrupt operations for the compliant providers who accept patients referred by them. Nearly a quarter of billing providers said they had been unable to obtain NPIs for 5% or more of such practitioners.

Other systemic problems include NPIs being stripped from the transaction by an intermediary before reaching its destination, reported by nearly half of providers responding, and difficulty meeting payer taxonomy (specialty code or facility type) requirements, listed by a similar number. Most disturbing, perhaps, is the almost 70% of providers who report receiving conflicting instructions from different health plans, such that “Fixing Payer A’s issue creates problems with Payer B.”

The survey results suggest that providers, who have been told for years now that the best NPI strategy is to update their records for accuracy and test early and often, seem to be discovering that inconsistencies beyond their control may ultimately make their NPI problems intractable. Even before the deadline, nearly 70% of providers report that payers are already rejecting, pending or losing claims based on NPI issues. 71.9% predict substantial payment disruptions if the nation goes to NPI-only on May 23, and 25% predict “substantial, immediate or short term service disruptions to patients.”

A most startling contrast came in the pharmacy segment, where a small cohort of providers reported great success sending their own NPIs, but dire problems collecting and submitting the new number for prescribers, who may offer only a scribbled signature for identification. Pharmacy Benefit Managers (PBMs), massive health plans that specialize in prescription coverage, showed a frightening big picture. Responses representing 101 million claims per month indicate that while almost 91% of claims were arriving with the pharmacies’ own NPIs, only 5.8% carried prescriber NPIs. Regulators recently posted an exceptionhandling allowance, but industry observers fear the guidance may be too little too late. One pharmacy respondent warns that “point of service rejects due to the nonacceptance of the legacy ID will result in customer service delays [and] risks of continuation of therapy.”

Comments collected in the survey suggest that providers, while most at risk, are not alone in their frustrations. One Medicare plan respondent stated that “There isn't enough time… to ensure there will be no disruption in payments.”

Providers report that this is already happening. One practitioner reported an inability to collect on Medicare claims since October, 2007. Another, a small hospital, said that the federal Centers for Medicare and Medicaid Services (CMS), which administers Medicare payments, had mixed up their NPI numbers, resulting in misrouted payments between three divisions which cost “many months trying to get it corrected. It caused cash flow to come to a halt for 2 weeks.”

A PBM respondent is alarmed that the NPI compliance date, May 23, 2008, falls on “a Friday before a holiday weekend, so after 5PM physician offices will not be available for stores to call for the NPI.” More than 8 million prescriptions are filled every day in the U.S.

As of May 9, Medicare continues to maintain its intention to deploy its NPI-only edits on May 23. Transactions submitted with a legacy ID for any provider identified on the claim, even referrers without an NPI, will be rejected.

The full report, “NPI Problems in Process,” and a free package containing the survey data and a public summary, is available at http://surveys.hittransition.com/npi .

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Sounds like what we need is a standard. Oh, wait...

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