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Paving the Way for the National Provider Identifier

May 26, 2006

Health care providers may be forced to use a National Provider Identifier (NPI) much sooner than the May 23, 2007 deadline, when the NPI will replace all existing provider numbers used to bill Medicare, Medicaid and other health care payers. (This deadline will not apply to small health plans, who will have until May 23, 2008 to comply with the NPI rule.)

On May 1, 2006, the Centers for Medicare and Medicaid Services (CMS) changed the CMS-855 Medicare enrollment applications requiring, among other things, providers and suppliers enrolling in or updating their information for the Medicare program to submit the NPI and a copy of the NPI notification furnished by the National Plan and Provider Enumeration System. Therefore, health care providers and suppliers that complete a CMS-855 form because they are new to the Medicare program or because they must update their enrollment information must convert to the NPI system now. Moreover, these health care providers must ensure that their business associates who conduct standard transactions on their behalf use the NPI appropriately.

The Health Insurance Portability and Accountability Act (HIPAA) of 1996 required the U.S. Department of Health and Human Services to adopt the NPI, which will facilitate billing among a variety of payers as well as other health information exchange initiatives that work to improve health and health care delivery.

Individual providers and sole proprietors are eligible for one NPI. Physicians and other providers who practice as part of a group may need to obtain an NPI for themselves as well as the corporation or LLC. Organizations may require an NPI for each of its "subparts" in order for those subparts to conduct standard transactions on their own behalf or to meet federal regulatory requirements related to their participation in health plans such as Medicare. Health care providers may obtain an NPI through one of three ways listed on the CMS website at

The health law attorneys at Godfrey & Kahn can guide health care providers through the NPI application process, as well as review Business Associate agreements to ensure that business associates comply with the NPI requirements.

If you have any questions or would like assistance regarding the NPI or any other health law issue, please contact Barbara Zabawa (608-284-2639 or or any member of Godfrey & Kahn’s Health Law Team.

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