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HIPAA NPI Contingency Plans

Health plans and payers are beginning to report the end dates of their NPI Claims Contingency Plans. Medicare has announced that effective March 1, Medicare fee-for-service claims must include an NPI in the primary provider fields (i.e., the billing, pay-to provider and rendering provider fields) or they will be rejected.  Additionally, many of the major health plans in Massachusetts have announced that their contingency plans will end as of May 23, 2008. Tufts Health Plan has already moved to accepting NPI only claims and other transaction submissions. See the chart below for more information.

Health Plan Implementation Dates for Claim Submissions (as of January, 2008)

Health Plan

Health Plan
Executing Contingency

Health Plan Contingency End Date

Plan Claim Form Requirement with Form Rejection

Medicare

Yes

3/1/ 2008

  • Medicare FFS 837P and CMS-1500 claims must include NPI in primary claim fields, failure to submit NPI in primary fields will result in claim reject
  • NPI only or NPI/legacy pairs can still be submitted in correct fields
  • Claims with both NPI and Medicare legacy #s rejected if the pair is not found on the Medicare NPI Crosswalk
  • Claims with only Medicare legacy in primary field rejected

5/23/2008

  • CMS will lift NPI contingency plan, and only accept NPI sent on all HIPAA electronic transaction (837I, 837P, NCPDP, 276/277, 270/271, and 835), paper claims and SPR remittance advice
  • CMS will stop sending legacy identifiers on COB crossover claims.

 1/1/2008

  • 837I electronic claims and UB-04 paper claims without an NPI in fields identifying the primary provider rejected
  • Legacy identifiers paired with NPIs (in primary provider fields) accepted in secondary provider fields

Blue Cross Blue Shield of MA

Yes

3/1/ 2008

  • Dual-use claims (with NPI & Legacy#) accepted until 5/23

No longer accept UB 92 claim forms. Still accepting older versions of CMS-1500 form & dental claim forms.

BMC HealthNet

Yes

5/23/ 2008

Currently accepting new & old forms. No plans to reject claims submitted on old forms between now & 5/23/08
Beacon Health Strategies

Yes

5/23/ 2008

Currently accepting new & old forms.

Fallon Community Health Plan

Yes

5/23/ 2008

Currently accepting both forms. Providers can use the old forms until their supplies are exhausted.

Harvard Pilgrim Health Care

Yes

5/23/ 2008

No longer accept UB-92 claim forms or CMS -1500 forms prior to “(rev. 08-05)”, or older versions of the dental claim forms.

Health New England

Yes

5/23/ 2008

Currently accepting new & old forms. No plans to reject claims submitted on old forms between now & 5/23/08

Mass Health

Yes

5/23/ 2008

No longer accepts UB-92 claim forms.  Accepting current version of proprietary forms, CMS 1500 and UB04; note crossover claims are accepted on 1500, as they always have been for professional billing

Neighborhod Health Plan

Yes

5/23/ 2008

Currently accepting new & old forms. No plans to reject claims submitted on old forms between now & 5/23/08
Network Health

Yes

5/23/ 2008

Currently accepting new & old forms. No plans to reject claims submitted on old forms between now & 5/23/08

Tufts Health Plan

No --
However, will accept legacy ID as secondary identifier

5/23/2007

  • NPIs were required as the primary identifier.
    5/23/2008

5/23/2008

  • Legacy ID will only be accepted as a secondary identifier until 5/23/08.

Currently accepting both old and new claim forms.

(Chart Source: Massachusetts Health Data Consortium NPI Advisory #13, January 2008.
Available at http://www.mahealthdata.org/hipaa/resources/identifiers/20080131_NPIAdvisory_13.pdf)


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