CMS has posted answers to 99 frequently asked questions about its contingency plan guidance for healthcare providers and others implementing a National Provider Identifier. The agency announced on April 2 that it is implementing a contingency plan for covered entities that will not meet the May 23, 2007, deadline for compliance with the NPI regulations; those entities that attempted to become NPI compliant can continue to accept legacy identifiers through May 23, 2008.
The FAQs range from “What should health care providers do with their NPIs while waiting for implementation instructions from their health plans?” (Answer: Protect NPIs from unauthorized use) to “Does this mean that providers have an additional 12 months to obtain and begin using NPIs?” (Answer: No; failure to obtain an NPI may be viewed as a violation of the good faith provisions of the contingency guidance.)
