Veterans Health Administration 11 th Annual HIPAA Summit –NPI Update C. David Mc Daniel Deputy Director, Business Development Michael Wierzbicki Standard Identifiers Component Liaison September 9, 2005

CBO … Putting ‘Business’ to work for America’s Veterans 2 The National Provider Identifier A standard, unique, 10-position, numeric identifier Maintained by Centers for Medicare and Medicaid Services (CMS) Required in HIPAA-standard electronic health care transactions Intended to universally identify trained, licensed providers of health care services and supplies Individuals (i.e. doctors and other health care practitioners) Organizations (e.g. hospitals and nursing homes)

CBO … Putting ‘Business’ to work for America’s Veterans 3 The National Provider Identifier Deadline: By May 23, 2007, HIPAA "covered entities" must use NPIs on all HIPAA-standard electronic transactions Therefore, NPIs are required for All billable health care practitioners providing health care services to VHA (a HIPAA-covered entity) VHA organizational providers

CBO … Putting ‘Business’ to work for America’s Veterans 4 Implementing the NPI The Department of Health and Human Services (HHS) contracted with an organization, known as the Enumerator, that receives and processes NPI applications by: Using the National Plan and Provider Enumeration System (NPPES) to uniquely identify each health care provider; Answering questions about NPI applications, assignments, and information updates; Collecting information, via applications and updates, to maintain the NPPES database (which contains NPIs and provider information).

CBO … Putting ‘Business’ to work for America’s Veterans 5 VHA’s Implementation of the NPI What is VHA doing about the NPI? Established an NPI Workgroup consisting of representative from VHA provider and health plan business lines; Brokered relationships with other federal agencies; Spreading the word to the provider community; Actively participating in the Workgroup for Electronic Data Interchange (WEDI) NPI Policy Advisory Group (PAG); and Preparing for bulk enumeration (enumeration is the process by which providers are assigned NPIs).

CBO … Putting ‘Business’ to work for America’s Veterans 6 Four Critical Processes Now Enumeration of Individual Providers Enumeration of Organizational Providers

CBO … Putting ‘Business’ to work for America’s Veterans 7 Four Critical Processes Now Preparation of the Revenue Cycle Preparation of Credentialing and Privileging to collect and maintain NPIs

CBO … Putting ‘Business’ to work for America’s Veterans 8 Enumeration of Individual Providers Awareness & Support Distribution & Verification Authorization, Application, & Enumeration Re-distribution & Implementation

CBO … Putting ‘Business’ to work for America’s Veterans 9 Designated the VHA Chief Business Office (CBO) as the lead in ensuring that providers can apply for, and receive, NPIs in bulk. Credentialing & Privileging to maintain enumeration Worked with VHA’s credentialing & privileging service on a process to receive the necessary provider information and send it to the Enumerator Received first pass of data in a database, which was created for the compilation of providers’ NPI application information Will refresh this data closer to the bulk distribution process Strategized about educating VHA providers and developed NPI educational materials for the field Participated in CMS’ NPI test program Identification of billable providers required to obtain an NPI (primarily at medical center and clinic levels, but some exist at lower levels) Met with VHA’s office of acquisitions to discuss how the NPI will affect contracting (i.e., changes to contracting requirements) Engaged union involvement to ensure that no difficulties were posed by VHA’s requirement for providers to obtain NPIs Enumeration of Providers

CBO … Putting ‘Business’ to work for America’s Veterans 10 Enumeration of Organizational Providers Identification of level of granularity for sub- parts Reconciliation with the way in which health care facilities are numbered (VHA-specific and federal tax ID number, etc) Anticipation of maintaining NPI application data in a dynamic environment

CBO … Putting ‘Business’ to work for America’s Veterans 11 HIPAA PMO to maintain enumeration of organizational providers In preparation for enumeration, developed database for storing organizational provider information Currently accomplished at the medical center and community clinic levels Verifying the appropriate level of enumeration of VHA subparts Enumeration of Organizational Providers (cont’d)

CBO … Putting ‘Business’ to work for America’s Veterans VAMCs (per VISN breakdown)

CBO … Putting ‘Business’ to work for America’s Veterans CBOCs (per VISN breakdown)

CBO … Putting ‘Business’ to work for America’s Veterans Sites (per VISN breakdown)

CBO … Putting ‘Business’ to work for America’s Veterans 15 Preparation of Revenue Cycle Identification of system and software changes needed Identification of business process changes needed Internal testing

CBO … Putting ‘Business’ to work for America’s Veterans 16 Preparation of EDI Revenue Systems Project manager identified for Electronic Data Interchange (EDI) Revenue Systems processes, not just internal billing Preliminary plan to address the changes that are being defined Expect to be testing these systems with payers by summer 2006 Anticipate payers will need time to work through back-end issues with elimination of current provider numbers On target for a May 2007 implementation of NPIs within the billing processes

CBO … Putting ‘Business’ to work for America’s Veterans 17 HIPAA: Nat'l Provider ID e-Payments Faster payment, Faster AR close- out e-MRA More accurate billing & AR Pre-registration Treatment Generate Receive Post Intake Claims & AR Payment Revenue VHA Revenue Cycle e-IIV More billing opportunities, Cleaner claims OHI, F-STOP Additional insurance data e-Denial Management Enhanced collections e-Claims Plus + e-Pharmacy Claims Faster payment, Drug Utilization Review (DUR) CIDC charge capture

CBO … Putting ‘Business’ to work for America’s Veterans 18 Preparation of Credentialing and Privileging to collect and maintain NPI Identification of necessary system and software changes Adding fields for the NPI Not adding taxonomy codes Identification of necessary business process changes Internal testing

CBO … Putting ‘Business’ to work for America’s Veterans 19 Scope of Providers Licensed independent providers Per data gathered 8/18/05 from Credentialing and Human Resources systems: 81,649 total providers have begun the credentialing process 53,466 active providers at some point in the credentialing process 46,549 appointed providers, credentialing completed

CBO … Putting ‘Business’ to work for America’s Veterans 20 Two More Critical Processes Identifying and communicating with trading partners Canvass VHA payer community to understand its needs Assess contract terms to validate NPI organizational outline Communicate with payer partners on phased (legacy, dual, and NPI-only) compliance approaches Software development and NPI Implementation that will not negatively impact the revenue cycle Gather requirements Design software Develop systems Conduct internal testing of interfacing systems and external testing with clearinghouse and payer partners

CBO … Putting ‘Business’ to work for America’s Veterans 21 Other NPI Preparation Drafted NPI official guidance in the form of a directive and handbook Discussed the NPI on appropriate national VHA calls Worked with Human Resources to obtain data to be used in bulk enumeration file Developed internal web site to compile and distribute providers’ NPI application information in preparation for NPI bulk enumeration Disseminated all approved educational material to the field via the VHA HIPAA PMO web site

CBO … Putting ‘Business’ to work for America’s Veterans 22 Expected Issues to Address Complexity of impact to organizational systems and business processes will be great Volume of providers to enumerate is significant Changes to credentialing and privileging process and systems to accommodate NPI must be completed Union and contracting changes to accommodate a requirement to have, maintain, and use an NPI will require negotiations (both internally and externally) Some trading partner limitations and complications remain to be fully understood and factored into the overall implementation strategy

CBO … Putting ‘Business’ to work for America’s Veterans 23 VHA Implementation Issues How much effort will be required to integrate the NPI into existing systems? Bulk enumerating individual and organizational providers with CMS Will CMS’ system be able to handle VHA’s bulk load? How far down into VA’s organization do we enumerate organizational providers? Billing or pay-to provider versus service provider How do we effectively spread the word about the NPI to all affected employees?

CBO … Putting ‘Business’ to work for America’s Veterans 24 Unexpected Issues to Address These factors add to the anticipated complexity of the changes necessary for migrating from legacy numbering systems: System of Records issues related to Privacy Act requirements Variables in provider types (licensed VS. non- licensed; billable VS. non-billable; interested in bulk enumeration VS. not interested; etc.) Communication challenges: reaching all providers who need to hear about the NPI Misinformation in the industry

CBO … Putting ‘Business’ to work for America’s Veterans 25 Misinformation Example “The requirement could mean that some physicians who are part of group practices and other arrangements would have multiple NPI numbers.” Source: Internal Medicine News, July 15, 2005.

CBO … Putting ‘Business’ to work for America’s Veterans 26 Industry Call to Action Begin dialog NOW (or months ago) Partnerships with provider and plan groups to discuss each other’s needs and anticipated problems Seek common ground to address some of the largest issues: Transition from legacy numbering systems Testing, scheduling, and EDI partnerships Maintaining revenue flow between plans and providers Speaking the same language, common interpretation of the Rule and not bogging down into minutia Learn from the industry’s mistakes in EDI