HIPAA requires that providers and payers use these standard identifiers for most administrative and financial transactions. The standards hold the potential to streamline processes, save time and cut costs by replacing the current hodge podge of confusing, conflicting identifiers.
Here's a snapshot on the status of the identifiers:
* The employer identifier is complete, with compliance required as of July 30, 2004.
* The provider identifier rule, issued in January 2004, outlined a 10-digit format. The identifier application process is well under way, although procedures for applying for more than one number at a time are still pending. And the deadline for compliance is May 23, 2007.
* The government's latest tentative deadline for issuing a proposed health plan (payer) identifier proposal is this coming June. Such issues as how to define a health plan and how many digits to use in the identifier have led to repeated delays.
In addition, a patient identifier is on indefinite hold because of Congressional concerns over privacy (see story, page 40).
Hurry up and wait
The ongoing delays in pinpointing the new identifiers and spelling out compliance methods have created an identity crisis of sorts for health care organizations struggling to figure out how to play by the rules. The Centers for Medicare and Medicaid Services in the Department of Health and Human Services is writing the rulebook.
"We are working on a lot of things throughout the agency," says Jim Bossenmeyer, director at CMS, in explaining the delays. "We need to develop the regulations in a timely manner, but we've always had to prioritize our workload."
Throughout the country, hospitals, clinics and managed care plans of all sizes, as well as individual physicians and other clinicians, are trying to figure out their HIPAA identifier strategies.
"Many people are late to the party and are just figuring out there's a lot to do," says Bill Larkin, vice president of business development at Fox Systems Inc., Scottsdale, Ariz. The vendor is the official enumerator for the National Provider Identifier and offers consulting services.
Among the many challenges are:
* Ensuring information systems can accept the National Provider Identifier and soon to be created health plan identifier.
* Determining if providers will apply for their own NPI or have their organizations do so through bulk enumeration.
* Determining when partner payers or providers will start using the NPI in transactions.
Employer ID easy
The employer rule was the first of the identifier mandates out of the gate, because coming up with a standard was relatively easy.
The rule called for using an employer's taxpayer ID number issued by the Internal Revenue Service as its standard Employer Identification Number. Because the taxpayer ID already was in widespread use in health care, the rule didn't garner much objection, nor did it require much modification in the policies of provider or payer organizations.
CMS enforces all non-privacy HIPAA rules through its Office for HIPAA Standards department. As of mid-November, the department hadn't received any noncompliance complaints about the EIN, says Stanley Nachimson, senior technical advisor at CMS.
Provider ID challenging
In stark contrast, the provider identifier rule is shaping up to be far more complicated.