Moderator: (Bill Finerfrock)
January 9, 2007
1:00 p.m. CT

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