The Notice of Proposed Rulemaking (NPRM) recommending the National Provider Identifier (NPI) as the standard health care provider identifier was published in the Federal Register on May 7, 1998. The NPRM is available from several sources:

• The Government Printing Office (GPO) website (www.access.gpo.gov/su_docs) is a link to the Federal Register. After going to that link, you would search on 1998 Federal Register. Link to Proposed Rules.

• A paper copy can be obtained by writing to New Orders, Superintendent of Documents, P.O. Box 371954, Pittsburgh, Pennsylvania 15250-7954. Specify the date of the issue requested and enclose a check or money order payable to the Superintendent of Documents, or enclose your Visa or Master Card number and expiration date. You may also place a credit card order by telephoning the order desk at (202) 512-1800, or by faxing to (202) 512-2250. Each copy costs $8.00.

• You can also view and copy the Federal Register at libraries designated as Federal Depository Libraries and at many public and academic libraries.

Currently, there is no universally accepted national identification and enumeration system for health care providers. Providers must use multiple identifiers for programs and organizations with which they do business. Data are not readily transportable among systems and, thus, must be collected redundantly. The problems and costs of exchanging provider data are great, hampering coordination of benefits and fraud and abuse detection efforts.

Organizations with a need to enumerate providers have joined in an effort, begun by the Health Care Financing Administration in 1993, to establish a national system for identifying and uniquely enumerating health care providers. The National Provider System has been designed to enumerate health care providers by assigning an identifier--the National Provider Identifier (NPI)--to each individual, organization, and group provider.

In July 1993, the Health Care Financing Administration (HCFA) undertook a project to develop a provider identification system to meet Medicare and Medicaid needs and ultimately a national identification system for all health care providers to meet the needs of other users and programs. HCFA convened a workgroup that included representatives from the private sector and Federal and State agencies who shared these same goals. Organizations that participated in this effort in addition to HCFA included:

• Department of Definse/OCHAMPUS
• Department of Health and Human Services/ASPE, PHS, FDA
• Department of Labor
• Department of Veterans Affairs
• Drug Enforcement Administration
• Office of Personnel Management
• Social Security Administration
• State Medicaid agencies and health departments, including those of Alabama, California, Pennsylvania, Minnesota, and Virginia
• Medicare contractors
• Professional and medical associations, including the American Medical Association, American Hospital Association, Health Insurance Association of America, and National Council of Prescription Drug Programs
• Regional consortia, including the Massachusetts Health Data Consortium, Utah Health Information Network, and Administrative Uniformity Committee of Minnesota
• Claims clearinghouses
• Standards groups, including the American National Standards Institute/Health Informatics Standards Planning Panel and the Accredited Standards Committee X12N Workgroup on Provider Information

Because of the limitations of existing identifiers, the workgroup advocated the development of a new identifier, called the National Provider Identifier (NPI), that would be in the public domain and that would incorporate the recommendations of the WEDI and ANSI workgroups. This new identifier, the National Provider Identifier (NPI), will use the extensive provider taxonomy being developed by the Accredited Standards Committee (ASC) X12N Workgroup on Provider Information. The ASC X12N provider taxonomy is available on the Internet at www.wpc-edi.com/Index.html.

In the NPRM, the National Provider Identifier (NPI) is proposed as an 8-position alphanumeric identifier. The NPI would contain no embedded intelligence; that is, information about the health care provider, such as the type of health care provider or State where the health care provider is located, would not be conveyed by the NPI. While this type of information would be recorded in the National Provider File, it would not be part of the identifier.

The eighth position of the NPI would be a numeric check digit which will assist in identifying erroneous or invalid NPIs. The check digit is a recognized International Standards Organization (ISO) standard. The check digit algorithm must be computed from an all-numeric base number. Therefore, any alpha characters that may be part of the NPI would be translated to specific numerics before the calculation of the check digit.

The NPI format would allow for the creation of approximately 20 billion unique identifiers.

On August 21, 1996, Congress passed the Health Insurance Portability and Accountability Act (HIPAA). HIPAA includes provisions to address the need for a standard health care provider identifier and other standards that would lead to administrative simplification. It mandates the establishment of these standards for use in the following electronic transactions: health claims, health encounter information, health claims attachments, health plan enrollments and disenrollments, health plan eligibility, health care payment and remittance advice, health plan premium payments, first report of injury, health claim status, and referral certification and authorization.

The Secretary of the Department of Health and Human Services (HHS) is charged with adopting the administrative simplification standards. The standards are applicable to health plans and health care clearinghouses that transmit any health information in electronic form in connection with the transactions listed above, and to health care providers that conduct electronically any of those transactions.

HIPAA stipulates the way in which the standards are to have been, or are to be, established, the consultations required, and the dates by which the standards must be set and implemented. HIPAA also gives HHS the authority to impose penalties on providers that conduct electronically any of the transactions listed above, health care clearinghouses, and health plans that delay, do not use, or misuse the standards. The process by which modifications and changes to standards may be made is also contained in this legislation.

In order to comply with HIPAA in establishing the standards, the Department of Health and Human Services (HHS) must rely on the recommendations of the National Committee on Vital and Health Statistics (NCVHS), consult with appropriate State, Federal, and private agencies or organizations, and publish the recommendations of NCVHS in the Federal Register.

HHS has organized interdepartmental implementation teams to identify and assess potential standards, including those for a health care provider identifier. A separate team addresses cross-cutting issues and coordinates the work of the implementation teams. The teams consult with NCVHS and standard setting organizations. The teams are charged with developing regulations and other necessary documents and making recommendations for the various standards to the HHS Data Council. (The Data Council is the focal point for consideration of data policy issues. It reports directly to the Secretary of HHS and advises her on data standards and privacy issues.)

HHS is developing recommendations for the standards to be adopted. The recommendations are being put in the form of Notices of Proposed Rulemaking (NPRMs) for publication the Federal Register. Each NPRM provides the public with a 60-day comment period. The public comments will be reviewed and analyzed, and Final Rules will then be published in the Federal Register; the Final Rules will announce the adoption of the standards.

The NPI NPRM defined a health care provider as an individual, group, or organization that provides medical or other health services or supplies. This definition includes physicians and other practitioners, physician/practitioner groups, institutions such as hospitals, laboratories, and nursing homes, organizations such as health maintenance organizations, and suppliers such as pharmacies and medical supply companies.

The proposed definition of a health care provider would not include health industry workers who support the provision of health care but who do not provide health services, such as admissions and billing personnel, housekeeping staff, and orderlies.

In the NPRM, we proposed and requested comments on two alternatives for defining the general categories of health care providers for enumeration purposes. The first alternative categorized health care providers as individuals, groups, or organizations. The second alternative categorized health care providers as individuals or organizations (groups would be considered organizations).

Individuals would be treated differently than organizations and groups because the data available to search for duplicates (for example, date and place of birth) are different. Organizations and groups may need to be treated differently from each other because it is possible that a group is not specifically licensed or certified to provide health care, whereas an organization usually is. It may, therefore, be important to be able to link the individual members to the group. It would not be possible to distinguish one category from another by looking at the NPI. The National Provider System (NPS) would contain the kinds of data necessary to uniquely identify each category of health care provider. Those categories are described as follows:

Individual--A human being who is licensed, certified or otherwise authorized to perform medical services or provide medical care, equipment or supplies in the normal course of business. Examples of individuals are physicians, nurses, dentists, pharmacists, and physical therapists.

Organization--An entity, other than an individual, that is licensed, certified or otherwise authorized to provide medical services, care, equipment or supplies in the normal course of business. The licensure, certification, or other recognition is granted to the organization entity. Individual owners, managers, or employees of the organization may also be certified, licensed, or otherwise recognized as individual health care providers in their own right. Each separate physical location of an organization, each member of an organization chain, and each subpart of an organization that needs to be identified would receive its own NPI. NPIs of organization providers (e.g., hospitals) would not be linked within the NPS to NPIs of other health care providers (e.g., physicians who work in the hospitals). Examples of organizations are hospitals, laboratories, ambulance companies, health maintenance organizations, and pharmacies.

The ownership of a group or organization can change if it is sold, consolidated, or merged, or if control changes due to stock acquisition. In many cases, the nature of the provider itself (for example, its location, staff or types of services provided) is not affected. In general, the NPI of the provider should not change in these situations.

We have had extensive consultations with health care providers, health plans, and members of health data standards organizations on the requirements for provider practice addresses and the group and organization structures in the National Provider System (NPS). Here are the major questions:

For: Practice addresses could aid in non-electronic matching of health care providers and in conversion of existing provider number systems to NPIs. They could be useful for research specific to practice location; for example, involving fraud or epidemiology.

Against: Practice addresses would be of limited use in the electronic identification and matching of health care providers. The large number of practice locations of some group providers, the frequent relocation of provider offices, and the temporary situations under which a health care provider may practice at a particular location would make maintenance of practice addresses burdensome and expensive.

Against: The large number of members of some groups and the frequent moves of individuals among groups would make national maintenance of group membership burdensome and expensive. Organizations that need to know group membership prefer to maintain this information locally, so that they can ensure its accuracy for their purposes.

For: The categorization of health care providers as individuals or organizations would provide flexibility for enumeration of integrated provider organizations. Eliminating the separate category of group providers would eliminate an artificial distinction between groups and organizations. It would eliminate the possibility that the same entity would be enumerated as both a group and an organization. It would eliminate any need for location codes for groups. It would allow enumeration at the lowest level that needs to be identified, offering flexibility for enumerators, health plans or other users of NPS data to link organization NPIs as they require in their own systems.

Against: A single business entity could have multiple NPIs, corresponding to its physical locations or subparts.

Below are two alternatives which illustrate how answers to the questions posed above would affect enumeration and health care provider data in the NPS. The results would depend upon whether the health care provider is an individual, organization, or group.

The NPS would capture practice addresses. It would assign a location code for each practice address of an individual or group provider. Organization and group providers would be distinguished and would have different associated data in the NPS. Organization providers could have only one location per NPI and could not have individuals listed as members. Group providers could have multiple locations with location codes per NPI and would have individuals listed as members.

For individual providers, the NPS would capture each practice address and assign a corresponding location code. The NPS would link the NPIs of individuals who are listed as members of a group with the NPI of their group.

For organization providers, the NPS would capture the single active practice address. It would not assign a corresponding location code.

The NPS would capture only one practice address for an individual or organization provider. It would not assign location codes. The NPS would not link the NPI of a group provider to the NPIs of individuals who are members of the group. Organization and group providers would not be distinguished from each other in the NPS. Each health care provider would be categorized as either an individual or an organization.

For individual providers, the NPS would capture a single practice address. It would not assign a corresponding location code.

For organization providers, each separate physical location or subpart that needed to be identified would receive its own NPI. The NPS would capture the single active practice address of the organization. It would not assign a corresponding location code.

Recent consultations with health care providers, health plans, and members of health data standards organizations have indicated a growing consensus for alternative 2 discussed above. Representatives of these organizations feel that alternative 2 will provide the data needed to identify the health care provider at the national level, while reducing burdensome data maintenance associated with provider practice location addresses and group membership. The Notice of Proposed Rulemaking will solicit comments on these and other alternatives for collection of practice location addresses and assignment of location codes, and on the group and organization provider data within the NPS.

Data integrity will be controlled on three levels: error prevention, ongoing monitoring, and active auditing. Error prevention will be assured by building into the National Provider System adequate data edits and logic checks, as well as by setting pre-editing standards for organizations that provide the data. Ongoing monitoring will track the consistency and validity of the data and resolve discrepancies resulting from the receipt of data from multiple sources. Periodic auditing will be established to ensure that the data re not just reasonable or logically possible but are, in fact, correct.

National Provider File Data Elements

KEY: I - Used for the identification of a provider.

A - Used for administrative purposes.

U - Included at the request of potential users (optional).

We need to consider the benefits of retaining all of the data elements shown in the table versus lowering the cost of maintaining the database by keeping only the minimum number of data elements needed for unique provider identification. The NPRM may solicit comments on the composition of the minimum set of data elements needed to uniquely identify each type of provider. In order to consider the inclusion or exclusion of data elements, we need to assess their purpose and use.

The data elements that we judge will be expensive to either validate or maintain (or both) are the license information, provider practice location addresses, and membership in groups. The NPRM solicited comments on whether these data elements are necessary for the unique enumeration of providers and whether validation or maintenance is required for that purpose.

Licenses may be critical in determining uniqueness of a health care provider (particularly in resolving identities involving compound surnames) and are, therefore, considered to be essential by some. License information is expensive to validate initially, but not expensive to maintain because it does not change frequently.

The practice location addresses can be used to aid in investigating possible provider matches, in converting existing provider numbers to NPIs, and in research involving fraud or epidemiology. Location codes could be assigned by the NPS to point to and identify practice locations of individuals and groups. Some potential users felt that practice addresses changed too frequently to be maintained efficiently at the national level. The average Medicare physician has two to three addresses at which he/she practices. Group providers may have many more practice locations. We estimate that 5 percent of health care providers require updates annually, and that addresses are one of the most frequently changing attributes. As a result, maintaining more than one practice address for a health care provider on a national scale could be burdensome and time consuming. Many potential users believe that practice addresses, if required by a health plan, could more adequately be maintained at local, health-plan specific levels. The NPRM solicited comments on these issues.

Some potential users felt that membership in groups was useful in identifying health care providers. Many others, however, felt that these data are highly volatile and costly to maintain. These users felt it was unlikely that membership in groups could be satisfactorily maintained at the national level. The NPRM solicited comments on capturing and maintaining membership in groups.

Certain information about individual providers must and will be protected in accordance with the Privacy Act. Enumerators, with on-line access to the National Provider File, will be required to adhere to the provisions of the Privacy Act. The National Provider System will maintain sophisticated technical and physical safeguards for the data.

The NPRM stated that separate Public Use Files would be available to the public, and a query and report facility separate from the National Provider System would be developed for public use.

We propose to charge fees for the dissemination of such items as data files and directories, but the fees would not exceed the cost of the dissemination.

For purposes of disseminating information from the National Provider File (NPF), we recommended in the NPRM the establishment of two levels of users. This is necessary because some of the information being collected in order to enumerate providers is confidential in nature and, as such, can only be released under the conditions of the Privacy Act.

Enumerators would have access to all data elements for all health care providers in order to accurately resolve potential duplicate situations (that is, the health care provider may already have been enumerated). Enumerators would be required to protect the privacy of the data in accordance with the Privacy Act.

Enumerators would have access to the on-line NPS and would also receive periodic batch update files from HCFA.

Selected data elements would be available to the public (which includes individuals, health care providers, software vendors, health plans that are not enumerators, and clearinghouses).

The table below lists the data comprising the NPF and indicates the proposed dissemination level (Level I or Level II).

Dissemination of Information from the National Provider File

Clearly, the access method to the public data would have to be electronic in order to support the more frequent users. The Notice of Proposed Rulemaking solicited comments on the kind of information that shuld be available in hardcopy, the types of electronic formats that would be needed (for example, diskette, CD ROM, tape, cartridge, and via Internet), and the frequency of update. These data would be made as widely available as feasible.

The National Provider System (NPS) will contain on-line enumeration screens with standardized data elements and definitions. To speed up processing and enhance data integrity, both initial enumerations and data updates will be performed as interactive, on-line processes. Standard queries and reports will be available to enumerators, along with daily extracts that will show all health care provider records which have been added or updated since the last extract. The NPS will provide enumerators with tutorial training software, user manuals, and access to a Help Desk to encourage timely and accurate submission of enumeration data.

Mandatory Data Elements for On-line Enumeration

Some data elements must be available and entered during the on-line enumeration in order to assign an NPI to a provider. Below is the list of these mandatory data elements.

FIRST NAME

LAST NAME

ADDRESS

CITY

COUNTRY - required if foreign address

FOREIGN POSTAL CODE - required if foreign address

STATE - required if not foreign address

ZIP CODE - required if not foreign address

PHONE

DATE OF BIRTH

STATE OF BIRTH - required if not foreign address

COUNTRY OF BIRTH - required if foreign address

LEGAL BUSINESS NAME

EMPLOYER IDENTIFICATION NUMBER

ADDRESS

CITY

COUNTRY - required if foreign address

FOREIGN POSTAL CODE - required if foreign address

STATE - required if not foreign address

ZIP CODE - required if not foreign address

PHONE

Each Group must have at least one Group Member:

MEMBER NPI

FIRST 2 CHARACTERS OF LAST NAME

Each Group must have at least one Practice Location:

ADDRESS

CITY

COUNTRY - required if foreign address

FOREIGN POSTAL CODE - required if foreign address

STATE - required if not foreign address

ZIP CODE - required if not foreign address

PHONE

LEGAL BUSINESS NAME

EMPLOYER IDENTIFICATION NUMBER

ADDRESS

CITY

COUNTRY - required if foreign address

FOREIGN POSTAL CODE - required if foreign address

STATE - required if not foreign address

ZIP CODE - required if not foreign address

PHONE

ADDRESS

CITY

COUNTRY - required if foreign address

FOREIGN POSTAL CODE - required if foreign address

STATE - required if not foreign address

ZIP CODE - required if not foreign address

PHONE

Each health care provider would be required to forward updates of its own data in the database to an NPI enumerator within 60 days of the date the change occurs. The NPRM solicited comments on whether such updates should be limited to only those data elements that are required to enumerate a health care provider (e.g., name, address).

The process of identifying and uniquely enumerating health care providers is separate from--but may be similar to--the process health plans follow in enrolling providers in their health programs. Even when the NPS begins assigning NPIs to health care providers, health plans would still have to follow their own procedures for receiving and verifying information from providers that apply to them for enrollment in their health programs.

Because the Medicare program maintains files on more health care providers than any other health care plan in the country, we envision using data from those files to initially populate the NPF that would be built by the NPS and accessed by the enumerator(s).

The major issue related to the operation of the enumeration process is determining who the enumerator(s) will be. Several choices are listed below, along with their advantages and disadvantages. This information was presented in the NPRM.

A central registry operated under Federal direction would enumerate all health care providers. The Federally-directed registry could be a single physical entity or could be a number of agents controlled by a single entity and operating under common procedures and oversight.

For: The process would be consistent; centralized operation would assure consistent data quality; the concept of a registry is easy to understand (single source for identifiers).

Against: The cost of creating a new entity rather than enumerating as part of existing functions (for example, plan enrollment) would be greater than having existing entities enumerate; there would be redundant data required for enumeration and enrollment in a health plan.

For: The organization(s) would operate in a consistent manner under uniform requirements and standards; failure to maintain prescribed requirements and standards could result in penalties which could include suspension or debarment from being an enumerator.

Against: A large number of private enumerators would compromise the quality of work and be more difficult to manage; the administrative work required to set up arrangements for a private enumerator(s) may be significant; the cost of creating a new entity rather than enumerating as part of existing functions (for example, plan enrollment) would be greater than having existing entities enumerate; there may be redundant data required for enumeration and enrollment in a health plan; the legality of privatization would need to be researched.

(Note: If private organizations as enumerators could charge health care providers a fee for obtaining NPIs, this enumeration option would be attractive and more preferable than the other choices or combinations, as it would offer a way to fund the enumeration function. In researching the legality of this approach, however, we were advised that we do not have the authority under the current law to (1) charge health care providers a fee for obtaining NPIs, or (2) license private organizations that would charge health care providers for NPIs. For these reasons, we will not present as a viable option in the Notice of Proposed Rulemaking (NPRM) the use of private organizations as enumerators.)

For: These health plans already assign numbers to their health care providers; a large percentage of health care providers do business with Federal health plans and Medicaid State agencies; there would be no appreciable costs for these health plans to enumerate as part of their enrollment process; a small number of enumerators would assure consistent data quality.

Against: Not all health care providers do business with any of these health plans; there would be the question of which health plan would enumerate the health care provider that participates in more than one; we estimate that approximately 5 percent of the State Medicaid agencies may decline to take on this additional task.

The Governor of each State would designate an agency to be responsible for enumerating health care providers within the State. The agency might be the State Medicaid agency, State licensing board, health department, or some other organization. Each State would have the flexibility to develop its most workable approach.

For: This choice would cover all health care providers; there would be a single source of enumeration in each State; States could devise the least expensive mechanisms (for example, assign NPI during licensing); license renewal cycles would assure periodic checks on data accuracy.

We would enlist professional organizations to enumerate their members and/or enable professional schools to enumerate their students.

For: Individuals could be enumerated at the beginning of their careers; most health care providers either attend a professional school or belong to an organization.

Against: Not all health care providers are affiliated with an organization or school; this choice would result in many enumerators and thus potentially lower the data quality; schools would not be in a position to update data once the health care provider has graduated; the choice would place an unfunded workload on schools and/or organizations.

Health plans in general would have access to the NPS to enumerate any of their health care providers.

For: Most health care providers do business with one or more health plans; there would be a relatively low cost for health plans to enumerate as part of enrollment; this choice would eliminate the need for redundant data.

Against: Not all health care providers are affiliated with a health plan; this choice would be confusing for the health care provider in determining which health plan would enumerate when the health care provider is enrolled in multiple health plans; there would be a very large number of enumerators and thus potentially serious data quality problems; the choice would place unfunded workload on health plans.

We also considered using combinations of these choices to maximize advantages and minimize disadvantages.

The two most viable options are described below. We solicited input on these options, as well as on alternate solutions, in the NPRM.

Option 1: Registry enumeration of all health care providers.

All health care providers would apply directly to a Federally-directed registry for an identifier. The registry would be operated by an agent or contractor. This option is favored by some health plans, which believe that a single entity should be given the task of enumerating health care providers and maintaining the database for the sake of consistency. It would also be the simplest option for providers, since enumeration activities would be carried out for all providers by a single entity. The major drawback to this option is the high cost of establishing a registry large enough to process enumeration and update requests for the 1.2 million current and 30,000 new (annually) providers who conduct HIPAA transactions. The statute did not provide a funding mechanism for the enumeration/update function. Federal funds, if available, could support the registry.

This option does not offer a clear possibility for funding some of the costs associated with the operation and maintenance of the National Provider System (NPS) once it becomes national in scope (that is, enumerates health care providers that are not Medicare health care providers). The NPRM solicited comments on appropriate methods for funding the NPS.

Federal programs and Medicaid State agencies would enumerate their own health care providers. Each health care provider participating in more than one health plan could choose the health plan by which it wishes to be enumerated. All other health care providers would be enumerated by a Federally-directed registry. These latter health care providers would apply directly to the registry for an identifier.

The number of enumerators, and the number of health care providers per enumerator, would be small enough to ensure careful validation of data. Moreover, enumerators (aside from the registry) would be dealing with their own health care providers, an advantage both in terms of cost equity and data quality. This option recognizes the fact that Federal programs and Medicaid State agencies already assign identifiers to their health care providers for their own programmatic purposes. It would standardize those existing processes and, in some cases, may increase the amount of data collected or validation performed.

We have concluded that the cost of concurrently enumerating and enrolling a Medicare provider is essentially the same as the cost of enrollment alone because of the high degree of redundancy between the processes. While there would probably be additional costs initially, they would be offset by savings in other areas (e.g., simplified, more efficient coordination of benefits; single enumeration of a health care provider; maintenance of only one identification number for a health care provider; maintenance of only one health care provider enumeration system).

The Federal Government is responsible for 75 percent of Medicaid State agency costs to enumerate and update health care providers. Because we believe the costs that would be incurred by Medicaid State agencies in enumerating and updating their own health care providers would be relatively low and offset by savings, we see no tangible costs involved.

Allowing these health plans to continue to enumerate their health care providers would reduce the registry workload and its operating costs. We estimate that approximately 85 percent of billing health care providers transact business with a Medicaid State agency or a Federal health plan. We estimate that 5 percent of Medicaid State agencies may decline to enumerate their health care providers. If so, that work would have to be absorbed by the registry. This expense could be offset by the discontinuance of the Unique Physician Identification Number (UPIN) registry, which is currently maintained with Federal funds. (The UPIN registry assigns, for the use of the Medicare program, an identification number to physicians and certain other health care providers.)

We solicited comments in the NPRM on the number of health care providers that would deal directly with a registry under this option and on alternative ways to enumerate them.

As with option 1, this option does not offer a clear possibility for funding some of the costs associated with the operation and maintenance of the NPS as it becomes national in scope. Again, in the NPRM, we solicited comments on appropriate methods for funding the NPS.

The NPRM stated that option 2 is more advantageous and less costly than option 1. Option 1 is the simplest for health care providers to understand but has a significant Federal budgetary impact. Option 2 takes advantage of existing expertise and processes to enumerate the majority of health care providers. This reduces the cost of the registry in option 2 to a point where it would be largely offset by savings from eliminating redundant enumeration processes.

Enumeration should occur in phases because the number of potential health care providers to be enumerated is too large to enumerate at one time, regardless of the number of enumerators. Below are the phases we recommended in the Notice of Proposed Rulemaking, described in the context of enumeration option 2 (enumerators would be a combination of Federal programs known as health plans, Medicaid State agencies, and a registry):

Health care providers that participate in Medicare would be enumerated first because, as the managing entity, HCFA has data readily available for all Medicare providers. Health care providers that are already enrolled in Medicare at the time of implementation would be enumerated based on existing Medicare provider databases that have already been reviewed and validated. These health care providers would not have to request an NPI--they would automatically receive one. After this initial enumeration, new health care providers not yet enumerated that wish to participate in Medicare would receive an NPI as a part of the enrollment process.

Concurrent with the second enumeration phase (described above), health care providers that do not transact any business with Federal health plans or Medicaid, but that do conduct electronically any of the transactions stipulated in HIPAA, would be enumerated by the Federally-directed registry.

After the first two phases of enumeration are completed, the remaining health care providers would be enumerated by the Federally-directed registry. This would be the third phase of enumeration. The health care providers to be enumerated in this phase are those that do not conduct electronically any of the transactions stipulated in HIPAA. In some cases, these health care providers may need to be enumerated because health plans may prefer to use the NPI for all health care providers, whether or not they submit HIPAA transactions electronically, for the sake of processing efficiency. In addition, some health care providers may wish to be enumerated even though they conduct no designated transactions and are not affiliated with any health plan. These health care providers would not be enumerated until all the health care providers requiring NPIs (i.e., those that conduct electronically any of the transactions specified by HIPAA) are enumerated.

The NPI has been endorsed by the following government and private organizations:

The Health Insurance Portability and Accountability Act, enacted in August 1996, requires that the Department of Health and Human Services (HHS) adopt standards for specified transactions and data elements (one of which is the health care provider identifier). Compliance with the standards is required no later than 24 months after the adoption of the standard (36 months for small health plans).

HHS has prepared and published in the Federal Register a Notice of Proposed Rulemaking (NPRM) that recommended the adoption of the National Provider Identifier (NPI) as the standard health care provider identifier. The NPRM was published in the Federal Register on May 7, 1998. The public comment period on the NPRM closed on July 6, 1998.

The comments are being analyzed and HHS will publish a Final Rule in the Federal Register. The Final Rule will announce the standard.

HCFA has received and responded to a number of questions concerning the National Provider Identifier and its implementation. Many of these questions were answered in the NPRM. Final resolution of many of these issues cannot occur until the Final Rule is published. We have compiled a list of the most frequently asked questions (FAQs) along with their answers. This list is updated on an ad hoc basis. View the FAQs.

This is the list of organizations and individuals who sent comments on the NPRM. The comments are available to the public from the DHHS administrative simplification website. That address is http://aspe.os.dhhs.gov/admnsimp/

View the List of Commenters on the NPI NPRM.

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Last Updated December 8, 1999