by Nick Jacobs

NPI numbers.

Just last week our CFO was expressing her deep concern over the fact that CMS was about to enforce a provision of the Health Insurance Portability and Accountability Act that would have required all claims to be accompanied by a national provider identifier or NPI.

When I asked for a further explanation from those present in the room who had expressed their concerns, I was informed that "They are requiring an NPI number on every form, but the forms don't have a place for the numbers." They clearly explained that it was the proverbial Catch 22. My chorus of accounts said, "They say we have to do it, but the billing companies aren't ready and some of the docs aren't ready and neither is CMS."

The most difficult part of the discussion for this CEO went something like this, "If we were not compliant, our funding would be interrupted." Okay, that was something that was very clear to me.

My first e-mail today came from our COO and it read a little like the prison scene where the governor calls at 11:59 PM just prior to the guard throwing the switch and says, "Okay, stay of execution."

CMS has, in fact, pushed back the deadline back by one year. Of course, there are still those who don't believe they can be ready even 12 months from May, but, for those of us who were just looking for a place to put the number, please join me in a big sigh of relief.

UPDATE: (from a hospital financial manager) No, CMS did not exactly come out and say that it is delayed for one year. What they are doing is announcing a "non-enforcement" approach for up to one year, that would still allow providers to receive their payments. However, to take advantage of this a covered entity must file "complaints" against other covered entities/business partners that are not yet compliant. A covered entity could be a provider, payer, clearinghouse, etc. Both sides must then develop contigency plans and show good faith efforts that they are working towards compliance. So, we may still want to be prepared for some sort of cash flow interruption until we hear more details about this "delay".