Expansion of the national provider identifier under a proposed rule published in April would be problematic, according to the Federation of American Hospitals.

The rule would require “organization covered” providers who are prescribers to obtain an NPI. These are providers such as hospitalists and residents who are not covered entities under HIPAA because they do not conduct standard transactions. Pharmacies, however, had had issues with getting claims without a NPI processed and the problem has become exacerbated under the Medicare Part D prescription drug benefit program.

For your consideration: A brief about a recent final rule making other NPI changes.

In a comment letter to the Centers for Medicare and Medicaid Services, FAH expresses concern that the proposal would require significant staff time for organizations to track and disclose individual NPIs for all providers who may prescribe ambulatory retail prescriptions. The HIPAA 5010 transaction standards, the federation notes, do not prohibit use of the group NPI for the prescriber ID, but nor are health plans prohibited from requiring the individual rather than group NPI.

“Although we understand that retail pharmacy claims may be rejected if prescribers have not obtained an individual NPI or have not revealed it during the prescription-writing process, we feel that it would be overly burdensome for hospitals to assume the responsibility for mandating, tracking and disclosing NPIs to any entity that requires them to process a claim,” the federal contends in its comment letter.

“For example, calls generated from retail pharmacies to emergency departments to verify NPIs of prescribing physicians may disrupt the care of patients. The provision of individual NPIs for non-office-based providers such as hospitalists and resident physicians would require hospitals to maintain a central location where this information is tracked as well as provide 24-hour staffing to provide these NPIs to retail pharmacies that are open 24 hours per day.”

FAH also commented on other provisions of the proposed rule to delay the ICD-10 compliance date to Oct. 1, 2014, establish a unique health plan identifier, and adopt an “Other Entity” identifier. The comment letter is available here.

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