Provider Identifier Standard (NPI)

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Medicare NPI Implementation

Timeframes

Medicare's implementation involving acceptance and processing of transactions with the NPI will occur in separate stages, as shown in the table below:

May 23, 2005 - Jan 2, 2006:	Providers should submit Medicare claims using only their existing Medicare numbers. They should not use their NPI numbers during this time period. CMS claims processing systems will reject, as unprocessable, any claim that includes an NPI during this phase.
Jan 3, 2006 - Oct 1, 2006:	Medicare systems will accept claims with an NPI, but an existing legacy Medicare number must also be on the claim. Note that CMS claims processing systems will reject, as unprocessable, any claim that includes only an NPI. Medicare will be capable of sending the NPI as primary provider identifier and legacy identifier as a secondary identifier in outbound claims, claim status response, and eligibility benefit response electronic transactions.
Oct 2, 2006 - May 22, 2007:	CMS systems will accept an existing legacy Medicare billing number and/or an NPI on claims. If there is any issue with the provider’s NPI and no Medicare legacy identifier is submitted, the provider may not be paid for the claim. Therefore, Medicare strongly recommends that providers, clearinghouses, and billing services continue to submit the Medicare legacy identifier as a secondary identifier. Medicare will be capable of sending the NPI as primary provider identifier and legacy identifier as a secondary identifier in outbound claim, claim status response, remittance advice (electronic but not paper), and eligibility response electronic transactions.
May 23, 2007 – Forward:	CMS systems will only accept NPI numbers. Small health plans have an additional year to be NPI compliant.

Medicare Organization Provider Subparts

The NPI Final Rule requires health care providers who are organizations and who are covered entities under HIPAA to determine if they have "subparts" that should be assigned NPIs. The NPI Final Rule provides guidance to those health care providers in making those determinations.

We have communicated to the Provider Enrollment staff at the carriers and fiscal intermediaries the Medicare program's expectations concerning the determination of subparts for NPI assignment purposes. We have prepared a document describing the subpart concept and its relationship to the way in which Medicare enrolls its organization providers. This document will be helpful to carrier and fiscal intermediary staff in understanding the issue of subparts and how subpart determination could be done in a way that helps to promote smoother and more efficient Medicare claims processing during the implementation of the NPI in the Medicare program.

The health care industry in general has expressed an interest in being informed of this type of information. We post it here so that it is easily available to interested parties.

Downloads
Medicare Subpart Expectations [PDF, 48KB]
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Page Last Modified: 1/27/06 3:25 PM
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