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March 27, 2018

Spring OPPS Update Released

The Centers for Medicare and Medicaid Services (CMS) summarized the spring update to the outpatie... Learn More

Therapy Caps Repealed and Payment for Therapy Assistant Services Lowered

Medicare payment caps on outpatient therapy were permanently repealed effective January 1, 2018. ... Learn More

OIG Update Work Plan, Studies Cardiac Device Credits

In March, the Office of Inspector General (OIG) posted several updates to its existing Work Plan,... Learn More

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Medical Coding News Archives

CMS Contingency Plan Coming to an End

February 12, 2008:
Medicare fee-for-service transactions will require providers to report only the national provider identifier (NPI) beginning May 23, 2008; legacy provider identifier numbers will no longer be permitted on form CMS-1500 or form CMS-1450 claims (except in certain the situations defined below). Claims containing legacy provider identifiers will be returned, without appeal rights.

The Health Insurance Portability and Accountability Act (HIPAA) of 1996 required that all physician, supplier, or other providers of health care that use HIPAA standard transactions obtain a unique NPI. The Centers for Medicare and Medicaid Services (CMS) also requires providers submitting nonelectronic claims (CMS 1500 and CMS 1450 [UB-04] claims) to report NPIs.

On April 2, 2007, the Department of Health and Human Services provided guidance to covered entities regarding contingency planning for implementing the NPI. As long as a health plan is compliant, meaning it can accept and send NPIs on electronic transactions, the plan could have established contingency plans to facilitate the compliance of trading partners. As a compliant health plan, Medicare fee for service (FFS) established a contingency plan on April 20, 2007, that followed this guidance. This contingency ends May 23, 2008.

CMS began to issue NPIs on May 23, 2005. The agency has been allowing transactions adopted under HIPAA to be submitted with a variety of identifiers such as:
  • NPI only
  • Medicare legacy only
  • NPI and legacy combination
However, claims not requiring an NPI—for example, for foreign claims, deceased provider claims, and other situations as allowed by CMS—will not be returned but instead will be processed in accordance with established procedures.

Deborah C. Hall
Clinical/Technical Editor


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