Operator:
Ladies and gentlemen, thank you for standing by
and welcome to today's RHC Technical Systems conference, NPI, Who
Needs Them, and Why. As a reminder, today's conference is being
recorded.
And now, I'd like to turn
the conference over to Mr. Bill Finerfrock.
Bill Finerfrock:
Thank you, operator, and
welcome everybody to today's Rural Health Clinic Technical Assistance
call. We have arranged for several speakers from the Centers for
Medicare and Medicaid Services to be with you this afternoon to
talk about the National Provider Identifier issue.
We have (Geri Nicholson),
who's with the Center for Medicare and Medicaid Services Officer
of (HEE) Health Standards and Services; (Pat Peyton), who's with
the CMS Office of Financial Management; (Laura Warfield) with Medicare
Implementation Team; and (Geri) is with the NPI Outreach, there
are other individuals here to answer other technical questions that
may arise during the course of today's call.
My name is Bill Finerfrock,
and I'm the Executive Director of the National Association of Rural
Health Clinics. (Geri) and her colleagues will address the continuing
confusion within the RHC community on why they need NPIs, how many
NPIs you need, and any other questions that continue to crop up,
or that you may have.
This call series is sponsored
by the Health Resources and Services Administration, Federal Office
of Rural Health Policy in conjunction with the National Association
of Rural Health Clinics. The purpose of the series is to provide
RHC staff and personnel with valuable technical assistance and information
on issues of interest to the RHC community.
Today's call is the fifteenth
in the series, this began late in 2004, and as you know from previous
participation, this project will continue for the next couple of
years. There is no charge to participate in this initiative, individuals
can sign up and receive announcements regarding call dates, topics
and speakers by going to (www.ruralhealth.hrsa.government/rhc).
During the question and
discussion segment of today's call, we ask that callers identify
themselves by name and location prior to asking your question.
Today's series presentation
is going to be a little bit different in that we won't have a formal
presentation with slides, the CMS staff are going to address some
issues that have been submitted to them in advance, and then we're
going to open it up for your questions for things that we may not
have covered, or things that have come up since we submitted the
questions.
In the future, as always,
if you have questions, send them to info, i-n-f-o, at narhc.org,
(info@narhc.org) and we will try and get them answered.
(Geri), welcome to you
and your colleagues there, and we look forward to learning more
about NPI and how it's affecting the RHC community.
(Geri Nicholson):
OK, thank you, Bill, and
thanks for putting this meeting together for us.
Today what we're going
to do is I'm going to talk a little bit first of all about the kind
of educational products we have out there, and where people can
get information about NPI, because I want to make sure you all know
that the information is there, and it's very comprehensive and can
answer many of your questions.
And then as you mentioned,
Bill, we're going to go through some of the questions we received
in advance, and following that presentation we'll just, you know,
listen to the audience, and see what else they need to hear about
from us.
So starting with just
letting everyone know that we have a dedicated Web site on cms.hhs.gov,
and if you go on that Web site, you'll see NPIs very prominently
displayed on many of the pages, and you'll just click. It'll take
you to our dedicated page that has a number of sections, we have
every communication that we put out to the provider community, and
we put information out through many different channels, including
associations through Medicaid agencies, through state survey agencies,
through our FIs and carriers, so we have a lot of people putting
information out to the providers, helping them to stay in touch
with what's going on with NPI.
We also have a page that
tells you how to apply for an NPI step by step, it's easy and it's
free, remember that, it's free. We have all of our educational resources
on another page, we have tip sheets, fact sheets, MLN matters, articles,
lots of information there for providers.
We have some enumeration
data that says - it has by state the type one and type two organizations,
it's account of really the type one and type two organizations that
have already enumerated by state.
We have also Medicare
NPI implementation information, because as you know, NPI is something
that applies to - across the country to every provider, to all health
plans, and each plan will have its own sort of way of implementing
NPI, and we want to make sure that those who bill Medicare understand
how Medicare will implement the NPI.
We also have another section
on what is called electronic file interchange, and that's a way
that an organization can enumerate many providers at one time, you
know, given their permission. And finally we have a resource for
different areas of the Web site where you can get questions answered.
And so that information is there, the URL, as I said, it's very
easy when you go on cms.hhs.gov, you'll see NPI immediately. But
if you want the exact URL to our NPI page, it's-www.cms.hhs.gov/nationalprovidentstand/
it's all one word, and that's all sort of one character string.
So with that, I'd like
to turn it over to (Pat Peyton), who works in our Office of Financial
Management, and who has been sort of a key analyst in developing
the NPI enumeration system, and answering a lot of questions about
NPI - Pat.
(Pat Peyton):
Hello, thanks, (Geri).
I have the series of questions that were submitted to us in advance,
and I can go over each question and answer them, if that's what
you would like me to do now. OK.
The first question was
do I need an NPI? And the answer to this is first of all you have
to be a healthcare provider to even be eligible to apply for an
NPI. And then according to the final rule, only the providers that
are covered entities under HIPAA, which are the providers that transmit
health data in electronic form in a connection with any of the HIPAA
standard transactions, they're covered providers, they're conducting
covered transactions, even if they may have a billing service or
a clearinghouse do it for them. Those covered providers are required
by the regulation to get NPIs.
Any healthcare provider,
however, is eligible to apply for an NPI. And all the - although
the regulation might not require a provider to have an NPI, there
could be health plans or employers that might require providers
to have NPIs, such as Medicare. Medicare is requiring its enrolled
providers to obtain NPIs.
Excuse me, and the same
thing, a hospital could require its employee providers to obtain
NPIs. And also there could be future uses of NPIs by lots of different
healthcare providers, perhaps in electronic health records, and
other transactions, and things to come in the future.
The second question was
can the clinic and the parent hospital have the same NPI?
Finerfrock:
(Pat)?
(Pat Peyton):
Yes.
Finerfrock:
Hold on, before we go on
to the next one, I just want to make it clear, when you use the
word healthcare provider, is that just an individual, or who is
defined as a healthcare provider?
(Pat Peyton):
A healthcare provider is
any entity, a person or an organization, who renders healthcare
as defined in the HIPAA regulations.
Finerfrock:
Because I think this is
a point that sometimes is confusing, that for purposes of the Medicare
program, the term healthcare provider is much broader - when you
say that to someone, they tend to think of it only as an individual,
a person is a healthcare provider. But a hospital, a rural health
clinic, a home health agency is also a healthcare provider, correct?
(Pat Peyton):
Right, yes they are.
Finerfrock:
OK, all right, I just wanted
to get that
(Pat Peyton):
No, that's a good point
- good point. The second question, can the clinic and the parent
hospital have the same NPI? And this is possible, but if the clinic
and the hospital each conduct their own HIPAA transactions, then
the hospital needs to make sure that the clinic, which would be
one of its sub-parts, gets its own NPI, and this is explained in
the final rule.
It is up to the parent,
in this case it will be the hospital, to look at its business requirements
and its situation, and determine if that clinic, if it doesn't do
its own HIPAA transactions, whether or not it really should have
an NPI. But this is a decision that the covered provider has to
make in accordance with the information that's in the final rule.
And we here in CMS also prepared a paper on sub-parts for our Medicare
providers, but we have posted it on the Web site that (Geri) gave
you earlier, it appears under Medicare NPI Implementation where
people can read a lot more information than what I'm giving you
right now about sub-parts.
Finerfrock:
So it is - it is up to the entity to decide whether
they do or they don't, it's not - it's not required, but it's determined
by the types of transactions that you're going to be involved in?
(Pat Peyton):
It's up to the parent, which is the covered provider,
to make the determination. But if any sub-part conducts its own
HIPAA transactions, that parent must make sure it gets its own NPI.
Finerfrock:
Can you give me an example of what would constitute
conducting its own HIPAA transaction?
(Pat Peyton):
Well take the hospital and the clinic, if the
clinic sends its own claims to a health plan, and the hospital doesn't
do it for it, then the clinic, if these are electric - electronic
claims, is acting as though it's a covered provider, and it needs
to have its own NPI. It would be identified as the billing provider
in those claims transactions.
On the other hand, if
the hospital does all the billing for the clinic, then it's up to
the hospital as to whether it wants the clinic to have an NPI or
not.
Finerfrock:
I think this is one of the areas, and it may be
where it's just spending a little bit of time here that it gets
a little confusing, because we have what are referred to as provider
based RHCs. And as a provider based RHC, their requirement is that
they are fully integrated into the parent entity for purposes of
financial management. And it - and it gets a little bit confusing
I think for folks as to what constitutes the hospital doing the
billing versus the RHC, I mean clearly they're being paid by Medicare
for an RHC service, not for a hospital service, but the hospital
is, you know, as the - as a provider base entity, the hospital is
the parent entity, and they're part - an integral part of that parent.
Is there any kind of bright
line test that - or should you just always presume that a provider
based RHC is because of an integral part, its billing is part of
the parent entity and wouldn't have a separate NPI?
(Pat Peyton):
Well if the parent entity does the billing, then
the final rule would not require the hospital to get the clinic
its own NPI. Each covered provider has to look at its own situation.
Finerfrock:
OK, maybe we'll get - some people may have more
specific questions when we get to that point. So we can go ahead
and move on.
(Pat Peyton):
OK. When can or should I start billing using the
NPI? Now this is a question where the providers are going to have
to check with the health plans to whom they send claims to find
out when those plans will be ready to accept NPIs in the claims
transactions, not to mention the other HIPAA transactions as well.
But I think most are working on the claim first.
For Medicare, Medicare
can accept NPIs along with legacy numbers in its standard claims
transactions right now, I can't speak for any other health plans,
however. But there is no purpose for a provider to start using an
NPI in its claims if that health plan can't yet do anything with
the NPI.
Finerfrock:
But your Medicare claims, they can use them now,
they can - they can currently bill using the NPI?
(Pat Peyton):
Yes, they can.
Finerfrock:
OK.
Female:
But we're also encouraging them to also submit
the legacy ID on the claim.
Finerfrock:
OK.
(Karen Trudell):
This is (Karen Trudell)
from the Office of E-Health Standards and Services, and I'd like
to suggest that all healthcare providers do start that dialog with
the plans to whom they submit claims to find out if they are ready
to take NPIs at this point, and to begin to submit them as soon
as possible. The plans need extra time to do testing; they need
to be able to build what we call crosswalks between the NPIs and
legacy identifiers so that they can connect up history to current
claims. And the sooner providers begin to submit NPIs on their claims,
the more effective and efficient that testing process is going to
be. So I would strongly suggest that people begin to talk to their
plans, look at their plan's Web sites, and find out whether they
can begin to submit NPIs, and to do that as soon as possible.
Finerfrock:
I think this is another area where there's been
some confusion. Because most of the - if not all of the information
that comes out about NPI is generated by CMS, I think a lot of people
believe that this is something that is only applicable to Medicare
or potentially Medicaid claims, without understanding that this
is also going to be populated and incorporated into the commercial
insurance world as well. Can you amplify on that, or expand on that
a little bit?
(Pat Peyton):
No, you're absolutely correct. The NPI requirements
apply to all HIPAA covered entities and all health plans are by
definition covered entities under HIPAA. So that includes Blue Cross
Blue Shield, Commercial Insurance, it includes managed care plans,
it includes employer plans, everyone.
Finerfrock:
Yes. And are the Medicare Advantage plans under
the - you guys are going - mandated use of NPI in May, correct?
Female:
Well that's when the
Female:
That's a national compliance date, that's - that
applies for everyone.
Finerfrock:
So all health plans will have to be compliant
at that point?
Female:
Yes.
Female:
Only small health plans have until May 23rd of
'08.
Finerfrock:
OK. All right, we - I think we can get into that
in the next question perhaps. Go ahead, I'm sorry. You can
(Pat Peyton):
OK. The next question was am I required to have
NPIs for my individual providers within my RHC? Again the regulation
requires only covered providers to have NPIs, so if those practitioners
within the RHC don't do their own claims, then they would not be
covered providers. Now keep in mind though, if any of those practitioners
are enrolled in Medicare, they're going to need to have an NPI.
If they're identified - and I'm speaking for Medicare now, Medicare
claims as rendering providers, I don't really know whether they
are or not, then they would need NPIs, because Medicare's going
to require that on their claims.
And also the parent hospital
or others could require them to have NPIs, but by regulation, if
they don't conduct any of the HIPAA transactions, they're not required
to get NPIs.
Finerfrock:
So in my rural health clinic, if I'm a rural health
clinic, and I have my NPI for my RHC claims, and then my physician
goes to see a patient in the hospital, which is not an RHC service,
but rather a Medicare Part B service, I need to have a separate
NPI for my physician in order for me to be able to submit that claim
to Medicare Part B?
(Pat Peyton):
Well the physician would get his or her own NPI,
and you would use it to identify that physician in your claim, and
that same NPI would identify that physician as a rendering provider,
whoever he may render services for, any group practice, or the hospital,
or anybody else.
Finerfrock:
OK.
(Karen Trudell):
This is (Karen) again.
That's a really critical point, that an individual provider does
not need a separate NPI for every organization with whom he or she
is affiliated, the whole point to an NPI for individuals is that
you have one identifier that carriers you through your entire career,
and it carries you through any association that you may have. And
a good rule of thumb in terms of in RHCs perspective is who on my
provider staff do I have to identify on a claim in order to get
reimbursed? Those individuals, those individual providers will need
NPIs, and the RHC will need to either make sure that the provider
has - is going to get an NPI, or will ask them to communicate the
NPI that they already have.
Finerfrock:
All right.
(Pat Peyton):
OK, now the next question really is the same as
the one I just read. Who within my RHC, doctors, physician assistants,
nurses, medical assistants, et cetera, should have an NPI? Again,
and like (Karen) said, if any of these practitioners are going to
need to be identified in your claim to Medicare anyway, they'll
need their NPIs. But again, by regulation, unless they're covered
providers, say it's not a Medicare claim, they would not need to
have NPIs.
What happens to my UPIN?
The UPINs are going to be phased out, and will not be able to be
entered on Medicare claims after May 23rd of 2007. These providers
with UPINs would be identified by NPIs or other means if they're
not covered providers, and not Medicare enrolled providers, and
otherwise choose not to get NPIs.
So I mean there's really
not much more to say about the UPIN. They're still being issued,
they're still being used right now, but come May 23rd, they won't
be anymore.
The next question is how
will contractors - and I'm assuming you mean Medicare contractors
Finerfrock:
yes.
(Pat Peyton):
claims processing - know I am an RHC when
I submit my bills? And they will know that because Medicare is developing
a cross walk that will link its legacy numbers to NPIs, and one
of the way that it's doing that is by encouraging all the providers
to use both their NPIs and their Medicare legacy numbers on their
claims to Medicare right now, that's called phase two of Medicare
NPI implementation. So if providers start doing that, then Medicare
can instantly start building that cross walk when those claims come
in.
If the RHC doesn't have
its own NPI, say it's a sub-part of the hospital, doesn't do its
own billing, and the hospital doesn't want it to have an NPI, the
hospital will be submitting the claims for the RHC. And the hospital's
NPI will be on there, and the hospital would likely be reporting,
because it will be using an NPI, taxonomy codes for itself and its
sub-parts. This is a new Medicare requirement. So Medicare would
know even though the RHC wouldn't be uniquely identified, that the
claim was for an RHC service.
The address and location
of the service, if it's performed at some place other than the billing
provider's address, is also on the 837 claim. Now I don't know how
much this comes into play with the RHCs or not, but you know, if
they're at an address different than the hospital, then that address
will be there, and that's another way that a health plan would know
where the service was performed.
Female:
(Pat), do you want to elaborate on what a taxonomy
code is for us?
(Pat Peyton):
Sure.
Finerfrock:
Yes, because we had a question on that that came
in separately, but go ahead.
(Pat Peyton):
OK, well a taxonomy - the healthcare provider
taxonomy code set is a classification of all of the different types
of healthcare providers, individuals and organizations and groups.
And actually there's some things in the healthcare provider taxonomy
codes that don't meet the HIPAA definition of a healthcare provider,
but those codes that existed before the NPI final rule ever came
along. It's the most comprehensive listing, it's a hierarchical
listing of healthcare provider types, hospitals are in there, every
physician specialty, all sorts of things.
So in some of these institutional
claims the hospitals will be sending using their NPIs, they would
indicate the taxonomy code of whatever sub-part performs a service.
Female:
So is there a taxonomy code specific to rural
health clinics?
(Pat Peyton):
Yes. And there's hundreds of codes in that code
set.
Finerfrock:
Now I don't know whether you have it, what I was
- what the question was is - and I don't have the list in front
of me, but there is - I know there is a rural health clinic one,
if anybody has it there. What I have ((inaudible)) is it's 261QR1300X,
does anyone there know if that's correct?
(Pat Peyton):
Here we don't have the taxonomy code set in front
of us, but I mean I can check on that and get back to you. It sounds
like a - like the correct format. But there are far too many for
me to be able to memorize
Female:
yes, we're working on that.
Finerfrock:
I certainly appreciate that, I didn't mean to
put you on the spot.
Female:
Oh no, that's OK; I'll let you know what it is.
Finerfrock:
And if you would get back to me, and then what
we'll do is send out an e-mail to all of the participants clarifying
or making - letting them know exactly what the taxonomy code is
for rural health clinic.
(Pat Peyton):
OK. And let me also mention, speaking of taxonomy
codes on the 837 claims, that is a situational data element, and
it is required if a health plan needs it to properly pay or adjudicate
the claim. So some health plans may want it, some health plans might
not.
Finerfrock:
OK.
(Pat Peyton):
And the last question you submitted ahead of time
was, does the NPI stay with the clinic even if it changes ownership,
or does the new owner apply for a new NPI? And the subject of changes
in ownership was addressed briefly in the NPI final rule, the final
rule explained how an NPI is to be a lasting identifier, and so
forth, as (Karen) mentioned earlier. It did say that in general,
if a provider has a new owner, it would still retain its same NPI,
actually the national plan and provider enumeration system doesn't
even capture ownership, so there'd be nothing even for a provider
to change in that database.
However, the final rule
doesn't define the term change of ownership, and as I'm sure all
of you know, there are many different things that are considered
ownership changes, and they're looked at in different ways by different
health plans and by different parts of the industry. And we are
asked a lot of times a question, do I need a new NPI? Basically
the final rule ((inaudible)) can be complex, and does leave the
final decision up to the healthcare providers themselves. We are
considering developing a frequently asked question about this, I'm
not sure, you know, when we would even have that posted. But it
can be a very complex issue. And the provider would be the one that
would ultimately determine whether it would deactivate the number
that exists now, and get a new number.
Now again that doesn't
apply to individuals, they're not owned or sold by anyone, their
NPIs, once they get them, last for their entire time that they furnish
healthcare.
Finerfrock:
And just to clarify, unlike some of the other
numbers that providers or clinics have had, the NPI is not what
is referred to as an intelligent number, in other words there's
no information that can be discerned from that number about the
provider as to, you know, well the first character means you're
a hospital, or it means you're a physician, it literally is just
a number that is randomly assigned, correct?
(Pat Peyton):
That's correct. And one rumor that I heard awhile
back was that if the NPI starts with a one, it means you're an individual,
and if it starts with a two, it means it's an organization, and
that's completely false.
Finerfrock:
Right, OK. I just - I've heard the same thing,
and I just wanted to put that out there to try and help quell whatever
rumors might exist, that you can not find it - you know, if someone
has your NPI or has access to an NPI, they get access to no information
about you.
(Pat Peyton):
That's correct.
Finerfrock:
OK. At this point, operator, if you want to open
up the lines, we can start taking some - well was there anything
else that you folks there wanted to say before we open it up to
questions?
(Geri Nicholson):
This is (Geri Nicholson),
the only thing I wanted to remind everyone listening about is that,
you know, we've been telling people that there's a certain amount
of work that has to happen after you get your NPI, and that may
take up to 120 days to really be ready for the compliance date.
So the important message is to enumerate, and then to start the
process and look at your internal business systems, to talk to your
billing vendors, to test with the various plans that you bill so
that you are ready on the compliance date. So enumeration is the
first step, but there's work after that, so we encourage everybody
to move quickly to get their NPI.
Finerfrock:
OK. Operator, we'll open it up. And again I want
to remind callers to please identify yourself by your name and location,
just you know, what state you're from, so we can get a sense of
the geographic distribution. We'll take a couple of calls off the
phone lines, and then I have a couple that were e-mailed in. So,
operator, if we could open it up.
Operator:
Certainly. Ladies and gentlemen, if you wish to
ask a question over the telephone today, please press star one on
your telephone. We'll proceed in the order that you signal us, and
a voice prompt on your phone line will indicate that your line has
been opened. Once again we ask that you do please state your name
and your location before posting your question. Once again it is
star one please. And we'll take our first question.
Finerfrock:
Go ahead, caller.
(Diane Davidson):
Yes, I'm (Diane Davidson)
from Farmerville, Louisiana. I'm with Union General Rural Health
Clinic. I have a question regarding the NPI number. We bill the
Part B professional services from our clinic, not from our provider
hospital. Is the NPI number that we received for the clinic going
to serve the same purpose for the Part B group billing for the inpatient
hospital services? Or do we need a second NPI number that normally
would be billed for Part B?
(Pat Peyton):
This is (Pat). If it's the same entity, it doesn't
need a different NPI, it can use its same NPI, it's still identifying
the same provider.
(Diane Davidson):
OK, so it will pay the
set rate when you bill the Part A, and then it will bill the group
rate when you bill the Part B, you just use the same - you just
will bill on say like the 1,500 to one and the (UB) on the other?
(Pat Peyton):
Well now I presume you're talking electronically,
because the 1,500
(Diane Davidson):
Correct, I mean it's -
I know it's got different numbers - I mean different electronic
numbers, but on the hard copy it would be that's how I relate it
too since I don't do the actual billing. But when you're billing
it to the different entities, the number is still the same, although
now they're different numbers.
(Pat Peyton):
Right and we mentioned in that sub-parts paper
that if a provider bills Medicare Part A and Part B, it does not
need two different NPIs.
(Diane Davidson):
OK, I just wanted to clarify
that, because the person who applied for those numbers is no longer
working with us, and we're just trying to be sure we've captured
all of the details that we weren't aware of.
(Pat Peyton):
OK.
(Diane Davidson):
Thank you.
Operator:
And we'll move on to our next question.
(Diane):
Hi, my name is (Diane); I'm calling from Bethlehem
Family Practice. We're a rural health clinic in Hickory, North Carolina.
And my question relates the NPI to the Medicaid number. Rural health
clinics have a Medicare number with an alpha suffix which relates
to whether it's a sick visit or a well visit. Is the NPI going to
replace the Medicaid number with the alpha suffix?
Female:
Well the NPI is going to replace the number that
the provider uses today to bill Medicaid, but Medicaid inside of
itself as part of its NPI implementation is going to have to link
that NPI to its legacy number internally so it'll know how to pay
you, and who you are.
(Diane):
OK. And second question, I received - when I received
my NPI number, I received a taxonomy code which is for family practice.
Now if after you research this question about the taxonomy code
for rural health clinics, do I need to go back and ask Medicare
to adjust anything on here or
Female:
Well that taxonomy code that appears on your notification
is the one that you or whoever reported when they applied for their
NPI.
(Diane):
OK.
Female:
And if you do find out that instead of being a
group - a family practice group, you should have been an RHC, that's
fine for you to change that information, you should change the information,
but it's not with Medicare, it's with the National Provider and
Plan Enumeration System, NPPES, it's the same ones who sent you
that notification.
(Diane):
OK.
Female:
So you can either go online and change your taxonomy
code if you decide that's what you want to do, or you can call the
enumerator and get a paper application form and change it using
the paper form, whichever you prefer.
(Diane):
OK. And someone will follow up to determine what
taxonomy code rural health clinics should be using, you know, we're
not associated with a hospital or anything else, and I don't think
they really call it free standing, I'm always
Finerfrock:
No, the taxonomy that I've seen is just simply
described as rural health clinic.
(Diane):
OK.
Female:
And I'll be sending Bill and e-mail with that.
(Diane):
OK, great.
Finerfrock:
And we will then send it out through the LISTSERV.
(Diane):
Right, thank you very
Finerfrock:
So if you're on the LISTSERV, you will get it.
(Diane):
Thank you very much, that's the last question
that I had.
Finerfrock:
OK.
Female:
You're welcome.
Operator:
And we'll take our next question.
Finerfrock:
Go ahead, caller.
Operator:
Caller, your line is open if you heard the voice
prompt.
(Arnett):
This is (Arnett) in North Carolina. We have a
provider who will be leaving and going to a practice that is not
rural health, will she need a different taxonomy code number if
ours is a rural health number? Or - and will she need a new number?
Female:
You're talking about an individual person?
(Arnett):
An individual person, yes.
Female:
Well when that person applied for his or her NPI,
I mean they gave the taxonomy code of what they are, a person wouldn't
be a rural health clinic.
(Arnett):
OK.
Finerfrock:
Right, presumably it was physician.
(Arnett):
Yes.
Female:
Right and that NPI will stay with that physician
no matter where that physician works in the future.
(Arnett):
OK. And suppose when we hire a replacement physician
for whatever reason they do not have an NPI number, how are we going
to handle that after May 23rd
Female:
Well you would simply tell that provider to obtain
an NPI, he certainly is eligible as a physician, you know, it only
takes a couple of minutes to apply on the Web.
(Arnett):
OK.
Female:
And then he would give you the NPI so that you
would have it for your records.
(Arnett):
OK. Now in our practice, we have obtained an NPI
for the rural health association which owns and operates the clinic,
and then our physician and our family nurse practitioner each have
an NPI number individually of their own.
Female:
That's good.
Female:
Right.
(Arnett):
Should we be billing under the rural health number
or under each individual provider?
Female:
You're going to continue to do that the same way
you do it now. If you use your rural health clinic number as the
billing provider, and then the PINs or the UPINs of each of the
individual providers as the rendering physician, you continue to
do that, you just substitute the RHCs NPI for whatever identifier
you're using now, and you substitute the individual practitioner's
NPI with however you're identifying them now as the rendering physician.
(Arnett):
OK
Female:
Really nothing different in terms of how you -
how you do the mechanics of the billing, you're just substituting
new numbers.
(Arnett):
OK. We currently are billing most of our claims
using the physician's number, even when the services are provided
by the family nurse practitioner. Is that the way we need to continue
to do that, or should we bill them with the family nurse practitioner's
NPI number?
Bill Finerfrock:
Let me - let me jump in
here a second, I'm a little bit confused by what you've just said.
You are a rural health clinic.
(Arnett):
Yes.
Bill Finerfrock:
And so when you submit
a rural health clinic claim, you should be using your rural health
clinic number, not your physician's number, but a rural health clinic
number.
Female:
No, Bill, she might need to use both. The rural
health clinic would be the billing provider.
Bill Finerfrock:
Right, but the
Female:
And see and
(Arnett):
we're using our rural health group number.
Female:
Yes.
(Arnett):
OK, but
Bill Finerfrock:
When you - when you -
when your physician or your nurse practitioner sees a non-RHC patient
or provides a non-RHC service to a Medicare patient, you would normally
want to bill that using the provider number of the provider who
delivered the service, although you do have the option under Medicare
Part B to use the physician's billing number for your nurse practitioner
if it can be defined as what is referred to as an incident to service.
Female:
How do
Female:
We don't
Bill Finerfrock:
OK?
(Arnett):
Actually all of our services that we provide are
rural health services.
Bill Finerfrock:
OK.
(Arnett):
So I guess we're having a conflict - or not a
conflict, but a misunderstanding as to who we should actually be
putting in as the rendering provider.
Bill Finerfrock:
Well it should be the
person who actually delivered the service. But perhaps this is a
conversation we could have off line, if you wanted to give me a
call
(Arnett):
OK.
Bill Finerfrock:
or send me an e-mail
(Arnett):
What is that number?
Bill Finerfrock:
we can discuss this separately.
(Arnett):
What number can I call you at?
Bill Finerfrock:
202-543-0348.
(Arnett):
OK, thank you, sir.
Bill Finerfrock:
OK.
Operator:
We'll move on to our next question.
Bill Finerfrock:
Yes.
(Merna):
This is (Merna) with Community Rural Health Clinics
in Onega, Kansas. And I just had a comment on the RHC taxonomy code.
The one that we were told to use is 207Q00000, there's five zeros
there, and an X at the end.
Bill Finerfrock:
Well I think we're going
to have to get that clarified. So what (Pat) is going to do is get
that, and I will get that out to the LISTSERV.
(Merna):
And then we also were told in December at the
workshop we went to as of January 1, 2007, all of our claims that
we're billing to Medicare Part A have got to have the taxonomy codes
on them, and along with that, you have to bill your NPI numbers.
So we're having a - we're having some problems with that because
the NPIs not required until May 23rd, but in order to get our claims
to go through, we have to have that taxonomy and NPI on as - for
dates of service as of January 1.
Female:
I think what that instruction is if you use an
NPI in those Medicare claims, you need to use a taxonomy code. If
you're not using your NPIs yet, you don't need to use the taxonomy
codes yet.
(Merna):
Oh we were told it's the other way around. If
- you have to have taxonomy on, and if you have taxonomy, you have
to have the NPI. So that's how they're processing them for us in
Kansas.
Female:
I know there's been a lot of confusion on that,
but we were just talking to the person that was responsible for
that instruction just this week, and that's what we were told.
Bill Finerfrock:
And so - and, (Merna),
who told you that?
(Merna):
We have Blue Cross Blue Shield out of Kansas is
our intermediary, and all of our claims came back on the RTP screen
for not having them on there.
Female:
If you can give details about that to Bill, and,
Bill, you can e-mail that to me, we'll look into it.
Bill Finerfrock:
OK, just, (Merna), if
you want to send it to me, or follow up to my e-mail
(Merna):
OK.
Bill Finerfrock:
to info, i-n-f-o at narhc.org.
(Merna):
OK.
Bill Finerfrock:
All right?
(Merna):
Will do, thank you.
Bill Finerfrock:
Let me - let me take a
couple of questions that were e-mailed in here. This one was from
(Ellen Shomberg), she said I represent central billing for four
RHCs, which include six physicians, an LCSW and four PAs or nurse
practitioners, and we're critical access hospital owned. My understanding
is that I need an NPI for each physician in each mid level as well
as the LCSW, I also need an NPI for each of the RHCs. Is this correct?
I think the answer is
yes. If the individuals - whoever is going to be doing a HIPAA transaction.
Female:
Right.
Bill Finerfrock:
I called the NPI specialist,
which could give her no advice.
Female:
May I say something right here, Bill, about that
now that you've touched on that? You shouldn't be calling that 800
NPI numerator number, no one should with any of these types of questions,
they all deal with a regulation.
Bill Finerfrock:
OK.
Female:
What the enumerator helps people with is actually
filling out the application, and if they've forgotten their NPI,
or they've lost their notification, or they're having trouble setting
up their user ID and password, things like that, but not, you know,
how many NPIs should I have, and things of that nature.
Bill Finerfrock:
OK.
Female:
Go ahead; I'm sorry, but
Bill Finerfrock:
No, that's all right,
that's a good point. And she says the hospital has a group number
for Medicare Part B claims, claims that are non RHC, such as inpatient
and observation that they use for Arkansas Blue Cross Blue Shield.
Do they need an NPI number for this group?
Female:
Well if this is a group that's sending claims
to a health plan, yes, it's required to have an NPI.
Bill Finerfrock:
OK. Next question is from
(Elsie Crawford). The person in our office in charge of credentialing
wants to know if the NPI is to be used in billing, why is it being
requested for referrals in addition to the UPIN? She's receiving
requests from hospitals, pharmacists and specialists we refer to.
Female:
Well the provider that sends the bill that has
to identify the ordering or referring provider needs to know the
NPI of whoever ordered or referred a patient - ordered a service
or referred a patient in order to complete their claim. So that's
why they're asking for their NPIs.
Bill Finerfrock:
So if I'm a - if I'm a
rural health clinic, and I send a patient to the radiologist for
an x-ray, that radiologist needs to know my NPI as an RHC in order
for the radiologist to be able to submit the bill.
Female:
That's correct.
Bill Finerfrock:
So that's why they're
asking for your NPI?
Female:
Right.
Bill Finerfrock:
OK.
Female:
And if
Doris McFarlin:
This is Doris McFarlin,
McFarlin Medical Clinic at Hillsboro, Illinois. And then I just
wonder then about the confidentiality then of sharing the NPIs,
and if a - if a physician refers to us for a pre-op exam, and we
need the NPI to bill that as a referring, but we send them to the
hospital for lab because they're having this surgery done, do we
then share the NPI of the surgeon with the hospital?
Female:
All of the providers have to share their NPIs
with any other entity that needs their NPI in order to submit a
claim or conduct any other HIPAA transaction where an NPI might
be needed. Covered providers are required to disclose their NPIs
to anyone that asks for them for that purpose.
Doris McFarlin:
So we would be protected
under HIPAA?
Female:
It's a requirement.
Female:
That's not - that's not protected health information
under the HIPAA privacy rule.
Doris McFarlin:
OK.
Bill Finerfrock:
That's because there's
nothing in the NPI that you can find out.
Female:
And it's - and it's not patient information, it's
a simple identifier
Female:
Right.
Female:
for a provider. And yes, that includes
a hospital who will need to identify the operating physician, a
laboratory who needs - a laboratory who needs to identify a provider
who referred a patient there for a test, all kinds of situations
like that, doctors that order DME for patients, the DME supplier
needs that number in order to submit the claim.
Bill Finerfrock:
Along those lines, has
there been any progress in getting the necessary authority through
HHS for making the NPIs available in a publicly available database?
Female:
You're speaking of the data dissemination notice,
which is
Bill Finerfrock:
Yes.
Female:
still in department clearance.
Bill Finerfrock:
OK, all right. Why don't
we take another call from the phone.
Operator:
Caller, your line is open.
Bill Finerfrock:
Go ahead, caller.
Female:
That was my question, Bill.
Bill Finerfrock:
OK. Thank you.
Operator:
We'll move on to the next one.
(Christy Knowles):
Hi, my name is (Christy
Knowles), and I am calling from Tennessee. My question is regarding
hospital owned clinics. If the hospital has already obtained their
own NPI, and they own this clinic, and it's - the clinic is a (DBA)
of the hospital, would they use the hospital's NPI, or would they
have to get another one for the clinic?
Female:
Well again this would be a sub-part of the hospital,
and if this clinic does its own claims, sends its own claims to
health plans, then the hospital needs to tell the clinic to get
an NPI.
(Christy Knowles):
OK, that's what I wanted
to make sure. Thank you.
Female:
You're welcome.
Operator:
And we'll move on.
(Susan Price):
Yes, this is (Susan Price) at Community Health
Clinic in Stephenville, Texas. My question is we're not having a
lot of cooperation or help with the payers as far as when they're
wanting our information. They're requesting a copy of the confirmation.
We did ours online through e-mail, and got back e-mail responses,
unfortunately we did ours in June of '05 before they fixed the system,
and not every one of the confirmation letters has the doctor's name
on it. Then about three months after that, they fixed that problem.
But that's the confirmation we have, and the payers are not wanting
to accept that as confirmation. Suggestions?
Female:
Well first of all, if a - if a provider like a
person got an NPI, it would - it would have to put their name on
that notification that comes back, I mean that's the name of the
provider.
(Susan Price):
No, the enumerator sent it to my e-mail; I'm the
contact person
Female:
Right.
(Susan Price):
and when they first started doing this
in June of '05, they gave you a tracking number, and then about
the next day or the day after, they would send you back a confirmation,
and you matched the tracking number back to that original, and that's
how you knew that's who the doctor was. This was back in June of
'05; I've got about 15 physicians that we did this for.
Female:
OK, well if you - that 800 number that I will
give you right now that I said you don't call for policy issues,
that's a number that you can call to get a fresh copy of a notification
that will have everything in it that it's supposed to have. I know
that they - the format of those notifications did change over time,
sometimes they weren't the same if they came in e-mail or in letter
form. But that 800 number is 1-800-465-3203, that's the NPI enumerator's
number, and they will be able to generate another copy of the notification
as it would look now if that's going to be useful to you.
(Susan Price):
I appreciate that, I'm just curious as to whether
other people are having issues with payers not wanting to accept
the documentation that we provide.
Female:
I've not heard of any payer refusing to accept
a notification that came from the (NPPEF) system. But I've never
heard of the ones that exist like what you said yours look like
either, but
(Susan Price):
I'll be glad to forward one to you so you can
see it if you want.
Female:
Oh I don't know. No, probably not, we'll get you
a good one.
(Susan Price):
Wonderful. Thank you.
Bill Finerfrock:
OK. Along those lines,
one of the things we've heard is when a new physician comes to a
practice, the practice applies for the NPI, the enumerator says
oh that physician already has an NPI, they go back to the physician,
the physician says I don't know anything about it. But someone,
possibly a hospital or former employer had applied. How do they
get that information and find the NPI if the physician doesn't even
know what their NPI is?
Female:
Well this is an example of where these providers
have to take responsibility for their NPIs, and where even though
they - their intentions were good, where group practices and hospitals
shouldn't be applying for NPIs for providers without asking their
permission first, because this happens quite a bit. The provider
is going to have to contact the enumerator if he doesn't have any
idea who got his NPI on his behalf, seems unbelievable to me. But
anyway, he would have to call the enumerator and figure out what
to do from there, what the NPI is, and get another copy of the notification.
Bill Finerfrock:
OK.
Female:
It happens all the time.
Bill Finerfrock:
It does, I mean it - and
I agree, but I think a lot of folks - you know, I mean one of the
things someone said to me is a physician - or a provider should
view their NPI the same as their DEA number, and be, you know, as
cognizant and secure with it as they are with that. But I don't
think that that's been happening.
Let me take a question
that was e-mailed in from the Wayne Medical Center. This involves
the Medicaid program; Medicaid has informed them that they need
a separate NPI for their RHC containing the Medicaid RHC legacy
number and a separate NPI for their group containing the Medicaid
group legacy number in order to continue to submit claims. They
said that's because the claim processing system looks at NPI number
first, and claim types second, while the fiscal intermediary looks
at claim type first, and then NPI.
We've heard conflicting
opinions on the need for both of these NPIs in previous conferences,
but since Medicaid is requiring this, can we get something in writing
showing this requirement from CMS? Our software company, Sage Software,
formerly WebMD, is telling us that they believe more than one group
RHC NPI is a misinterpretation of the guidelines, and they may not
be able to develop the software changes to accommodate this since
it's not in writing from CMS.
However, if they had something
from CMS stating the necessity, it would prompt them to create the
necessary changes. Can you comment on that at all?
Female:
Well I - and back to the very beginning of what
you said, we're talking about one entity, correct?
Bill Finerfrock:
It's a rural health clinic
that apparently is also a group. And they're telling them that they
need a separate NPI for the RHC, and a separate NPI for the group.
Female:
Well the provider ought to know what it is, I
don't think it can be two different things. Medicaid may have it
enrolled as two different things, but if it is - that's because
maybe one does one type of service for Medicaid or something like
that. But the decision is the provider's as to how many NPIs it
gets based only on that business about do different locations or
different sub-parts submit their own claims, but electronically.
Female:
Bill, I think it would be very helpful if we could
get a little bit more information about this issue, most specifically
which state is involved, and talk to our Medicaid or regional office
folks to find some more information out about the specifics here.
Bill Finerfrock:
This is Missouri, what
I can do is forward the e-mail
Female:
Thank you.
Bill Finerfrock:
and who do you want me to send it
to? To (Pat)?
(Geri Nicholson):
You can - you can send
it to me, (Geri Nicholson), and I'll get it out to the right people.
Bill Finerfrock:
OK, I'll do that. We'll
take another question from the phones.
Operator:
Certainly. We'll take our next one.
Female:
Hello?
Bill Finerfrock:
Hello.
Female:
Yes, I have a question, but it's not with NPI.
Bill Finerfrock:
Well I don't know that
we're going to be able to help you.
Female:
OK, well it's - we bill a 99397 on line one, and
a (GO102) or (GO101) on line two.
Bill Finerfrock:
I don't think there's
anybody on the call today that can help you.
Female:
OK. Thanks.
Bill Finerfrock:
Great, thank you. Unless
one of you guys wanted to take a stab at that.
Female:
We really don't have the billing expertise
Bill Finerfrock:
I knew that, I'm just
kidding. Next call?
Operator:
Caller, your line is open, please go ahead.
(Lucy):
Hi, this is (Lucy) with the rural health clinic
in Forks, Washington. And my question is on the paper claims, where
do we put the taxonomy code?
Female:
Medicare has sent out instructions about its requirements
for the paper claim forms, and the National Uniform Claim Committee
and the National Uniform Billing Committee that are responsible
for the institutional and professional paper claims also have, you
know, like have written general instructions about it. We don't
have those here with us, but all the Medicare instructions are available
on the CMS Web site which would answer the question that you have.
(Lucy):
OK. We've been looking this morning, and have
not been able to find that information exactly where it goes, but
we'll continue to look.
Female:
Well I can send Bill a note, I have that back
at my desk where, you know, the Web page to go to.
(Lucy):
OK.
Bill Finerfrock:
And we'll put that out
on the LISTSERV then, along with the taxonomy code.
(Lucy):
Great, thank you.
Bill Finerfrock:
OK. Let me take one of
the e-mail questions. I'm not sure if I understand it, maybe it'll
make some sense to you. But I got an NPI - this is from (Marge Barber)
- I got an NPI from my RHCs with specific provider number, and one
for each of my individual providers. So I also need an NPI for my
physician's Medicare group, and my PAs Medicare group number. Or
can I just list these two groups numbers in the add an identifier
section approximately the fourth page of the NPI enrollment form
of my existing RHC and provider setups? Does that make any sense?
Female:
Well not really. I mean I don't know that I totally
understand, I mean if the - if the physician is a member of a group
in addition to working for the RHC, then that group would have to
get its own NPI.
Bill Finerfrock:
Right. It sounds like
there's a separate PA group too, which I don't understand. OK, but
I think we've tried to address that in terms of the distinction
between the groups and the individuals. Let's see
Female:
Right.
Bill Finerfrock:
how are we doing on time? I'm not
- I think we have about five more minutes, or are we up on our time?
Female:
Yes, about five more minutes.
Bill Finerfrock:
OK. Other calls from the
phones?
Operator:
Yes, we do have ((inaudible)). We'll take the
next one.
Bill Finerfrock:
Go ahead.
(Kristen):
This is (Kristen) from Jacobson Memorial Hospital
in Elgin, North Dakota. And I'm wondering on the Internet right
now we can go into upinregistry.com and find out the doctor's UPINs.
Is there going to be an NPI registry like that?
Female:
This is one of the questions that'll be answered
in the data dissemination notice that we're going to be publishing.
But we're not, you know, the notice is still in clearance, so we're
not at liberty to discuss the contents of it as, you know, something
could change throughout the clearance process.
Female:
But I think it is safe to say that there will
be - there will be some utilities for providers to find out the
NPIs of other providers if they need them.
(Kristen):
OK, thank you.
Operator:
And we'll take our next question.
Bill Finerfrock:
OK. Go ahead.
(Terry):
Yes, this is (Terry) from Nebraska calling. And
I had just a question regarding the NPIs again. We have a critical
access hospital with a rural health clinic attached, which I have
an NPI for. We are getting ready to open two separate satellite
clinics that'll be rural health. Each of those clinics need their
own NPI though all the billing will come through the home office,
or can we use one NPI for all three clinics?
Female:
If all the billing is coming through the home
office, well the home office would get an NPI as being the covered
provider. There's no reason for you to get NPIs for each one if
they're not doing their own transactions.
Bill Finerfrock:
Are you saying all of
your billing, or all of just - all of your Medicare billing, what
if it's a commercial insured individual, what if it's a Medicaid
individual, what if it's some other payer, that all is still going
through the parent provider?
(Terry):
Yes, it is.
Bill Finerfrock:
OK.
(Terry):
And then just in response when you were talking
about a provider not knowing his NPI, we have come across that,
the provider calls the enumerator line, they will give him based
on his birth date, social security number, they will give him a
user number, a user password, he can then go in, find his NPI, and
make any changes or corrections to it.
Female:
OK. Good.
Bill Finerfrock:
Thanks for that information,
that's helpful.
Operator:
We'll take our next question
Bill Finerfrock:
Here's a question, I think
again we've probably been over this, but RHCs have a home office,
the home office has the traditional provider number that is used
for filing the home office cost report. Is it appropriate for the
home office to retain its current traditional provider number as
it does not perform the standard transactions defined by HIPAA,
or does the home office also need an NPI? And if they're not performing
HIPAA transactions, they don't need an NPI.
Female:
But is the home office - I mean are we talking
about a legal entity here that's not part of a hospital?
Bill Finerfrock:
I don't know, I - it's
a - I'm not - I mean home office has no legal meaning to me, so
I'm not sure what that refers to.
Female:
Well it sounds as though that is the entity that
Medicare recognizes as being the provider.
Female:
Right, and even though it might not do the transactions,
its various sub-parts, the different locations of the RHCs
Bill Finerfrock:
Right.
Female:
would be. So we have indicated in previous
forums that that - it would need to have an NPI.
Bill Finerfrock:
And retaining the traditional
provider number, the traditional provider number is going to be
phased out anyway, so there's not an issue of them retaining it.
Female:
Well now the legacy numbers, you know, I think
Medicare - it depends on the provider type, you know, we're - we
may still issue them, but if those numbers are used for purposes
other than HIPAA standard transactions, we still may be issuing
them and providers still might be using them, like on cost reports
and things like that.
Bill Finerfrock:
OK. Question I had is
if an NPI goes unused, will it be suspended, you know, how with
the UPIN numbers if they're not used over a period of time, Medicare
will suspend the provider number. Would the same thing occur with
a - with an NPI?
Female:
Well once the NPI becomes a billing number, I
guess a health plan could suspend claims coming in from that NPI,
but in the National Plan Provider Enumeration System, you know,
all those NPIs stay there, no health plan can go into that system
and change anything. A provider can deactivate its NPI, you know,
like if it goes out of business or retires. But certainly if NPIs
are going to be billing numbers, and health plans want to, you know,
I don't know what proper term maybe they should use, but don't want
to accept - or don't want to pay claims, or want to discontinue
billing privileges to a number that hasn't sent the claim in X number
of months, they could still do that, and so with that health plan,
that number would not be usable.
Bill Finerfrock:
So unlike a provider number,
which would - could go away, the NPI will remain forever, it's just
whether or not it's an active billing number is subject to the individual
plan policy.
Female:
Right, I mean you could maybe be deactivated for
Medicare as far as that goes, but maybe you're still sending claims
to Medicaid, so your NPI is still a good number with that other
health plan.
Bill Finerfrock:
OK.
(Geri Nicholson):
Yes, this is (Geri); I
just want to reemphasize that the NPI is a national number that
would be used for billing, you know, plans across the country. For
Medicare's purposes, we're trying to be very clear on what Medicare's
rules would be, and that's why we have a section on our dedicated
Web page about NPI that refers to Medicare instructions. At some
point there may be an instruction that says, you know, if you haven't
submitted a claim for X period of time, we're going to deactivate
essentially your enrollment in the Medicare program, we won't accept
claims. But that would be a Medicare policy.
And in that same date
I want to emphasize that getting an NPI doesn't give you any billing
rights to any plan, you still have to be enrolled in that plan.
Bill Finerfrock:
Right.
(Geri Nicholson):
And so NPI is just simply
the national identifier that's subject to all of the national regulation
requirements that (Pat) has referred to throughout this call.
Bill Finerfrock:
I think we've probably
come up and used as much of your time as we are allowed to, and
I appreciate all of the time you've taken to be with us here today.
All of the folks from CMS who've generously given of your time to
help answer questions. I want to thank all of our participants today
for their time here on the questions that you've asked, I think
we've had some great questions, and I think you've helped to shed
light on the fact that there's still a lot of confusion out there
I think is the best way to describe it.
A transcript of today's
call will be available on the ORHP Web site hopefully in about a
week or so. I want to remind everybody to encourage others who may
be interested in register for the rural health clinic technical
assistance series. The next call is tentatively scheduled for Tuesday,
March 13th, topic and presenter information will be announced shortly.
I want to also remind
folks that the next call, if you haven't, encourage others to register
for the call series, and I want to suggest that in the future as
folks call in to call in shortly before the call ((inaudible)) begin
on time.
Thank you again, thank
you to the Office of Rural Health Policy for sponsoring this, and
to the folks at CMS for participating - operator.
Operator:
Ladies and gentlemen, that does conclude our conference
today. We thank you for your participation, have a great day.
END
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