The Centers for Medicare and Medicaid Services announced on April 2 that it is implementing a contingency plan for covered entities (other than small health plans) that will not meet the May 23, 2007, deadline for compliance with the National Provider Identifier regulations under the Health Insurance Portability and Accountability Act. CMS decided to announce this guidance after it became apparent that many covered entities would not be able to fully comply with the NPI standard by May 23. This guidance protects covered entities from enforcement action if they continue to act in good faith to come into compliance.
The enforcement process is complaint driven and will allow covered entities to demonstrate good faith efforts and employ contingency plans. If a complaint is filed against a covered entity, CMS will evaluate the entity’s “good faith efforts” to comply with the standards and will not impose penalties on covered entities that have deployed contingencies to ensure that the smooth flow of payment continues. Each covered entity will determine the specifics of its contingency plan. Contingency plans may not extend beyond May 23, 2008, but entities may elect to end their contingency plans sooner. Medicare plans to announce its own contingency plan shortly. Read the guidance.
