"Our plans see the benefit to the additional 12 months because it enables them, providers and clearinghouses to really form a collaborative to do this and not have it be a rushed effort," he says. "They want to make sure it's done right."
Blues plans also hope to use the extra time to verify the NPIs they've collected with the National Plan/Provider Enumeration System, which CMS recently enabled access to in an effort to help industry compliance, Birnbaum adds.
But providers, payers and clearinghouses covered under HIPAA don't have to take the full 12-month extension for their NPI contingency plan, according to the recent guidance.
The Blues association is sharing NPI readiness information among its members as well as with CMS to help the agency determine how many transactions are being submitted in compliance with the NPI rule. They are doing so to help the agency figure out when to end the contingency period.
Many Blues plans hope to follow similar methodology for determining the length of their own contingency plans, says Joel Slackman, managing director, policy at the Blues association.
"We're actively working with Medicare to ensure that we have a consensus methodology for determining when it's time to end contingency plans," he says. "We want to do this so that when Medicare triggers a notice for the end of its contingency plan, our health plans will be on the same page."
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