On May 23^rd, the NPI (National Provider Identifier) will be the required identifier on all claims. While most providers have gotten the message and obtained an NPI, many health plans are not prepared to process claims using this identifier. In addition to this issue, some software vendors have not completed reprogramming for the NPI and many have not completed successful testing.

During the testing phase, a number of issues that could delay claims payments have been identified. As a result, on February 15th the National Committee on Vital and Health Statistics (NCVHS) sent a letter to HHS Secretary Mike Leavitt, urging the Secretary to adopt a contingency plan, "similar to the one utilized for the transaction and code set standards in 2003," because there is a lack of confidence that everyone will be ready to "go live" with the NPI on May 23rd as planned.

The contingency plan envisioned by NCVHS would "...protect otherwise compliant covered entities from enforcement action if they develop and implement contingency plans, such as continuing to accept legacy identifiers, to assure continuity of operations." NCVHS made several recommendations to the Secretary:

Recommendation #1: NCVHS recommends that HHS/CMS take the lead to provide this education, while also enlisting the participation of organizations that represent the healthcare industry. Several of these organizations expressed a willingness to provide assistance in the effort.

Recommendation #2: NCVHS strongly recommends that HHS decide what NPPES information will be made available to the industry, issue a data dissemination notice, and make the data available at the earliest date possible. We believe this is essential to the success of NPI implementation.

Recommendation #3: NCVHS recommends that covered entities be required to accomplish these tasks by the May 23, 2007 compliance date.

Recommendation #4: NCVHS recommends that HHS publish contingency guidance similar to the one utilized for the transaction and code set standards in 2003. Such guidance would protect otherwise compliant covered entities from enforcement action if they develop and implement contingency plans, such as continuing to accept legacy identifiers, to assure continuity of operations. We suggest it would be prudent to institute a six-month contingency using the following conditions:

• If HHS issues the data dissemination notice and makes NPPES data available to the industry prior to or on May 23, 2007, the contingency period would end six months later, on November 23, 2007.
• If HHS issues the data dissemination notice and makes NPPES data available after May 23, 2007, the contingency period would end six months after the date the data are available.