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DHHS Issues National Provider Identifier Regulations

January 31, 2004

Background

On January 23, 2004, the U.S. Department of Health and Human Services ("DHHS") issued the Standard Unique Health Identifier for Health Care Providers under HIPAA (the "Final Rule").  The Final Rule adopts the National Provider Identifier ("NPI") as the standard unique identifier for covered health care providers.  The National Provider System is designated as the entity assigning and maintaining NPIs under federal direction.  The NPI will be ten digits in length, and each health care provider will have its own unique NPI.  The NPI will not be embedded with information about the health care provider.

Effective Date

The effective date of the Final Rule is May 23, 2005, and the compliance date is May 23, 2007 for covered entities, except "small health plans" that must comply with the Final Rule by May 23, 2008. 

Applications

Beginning May 23, 2005, covered health care providers (as defined by HIPAA) may apply for NPIs.  Both paper and electronic applications for NPIs will be permitted.  The Final Rule also contemplates the issuance of NPIs to "subparts" of health care organizations in certain circumstances.  Health care providers that are not covered entities under HIPAA may, but are not required, to apply for NPIs.

NPI Usage

On and after May 23, 2007, a covered health care provider must:
    * use its NPI to identify itself on all standard transactions;
    * disclose its NPI upon request for another entity's use in a standard transaction;
    * communicate any changes in its required data elements to the National Provider System within 30 days of the change;
    * require its business associates to use its NPI in all standard transactions; and
    * require each of its "subparts" to comply separately with the Final Rule if the health care provider has been issued more than one NPI for such subparts.

Additionally, health plans (except "small health plans") and health care clearinghouses must use the NPI of any health care provider or "subpart" on all standard transactions on or after May 23, 2007. 

We will provide more details about the Final Rule in an upcoming edition of HIPAA Law Focus.  If you have any questions about the Final Rule, please contact any of the following members of HMSC's HIPAA Compliance Team:

Gregory R. Schermerhorn    313-465-7638    gschermerhorn@Honigman.com