NPI Data Dissemination Alert

Clinical social workers who have applied for a National Provider Identifier have until June 30, 2007 to revise or update information provided as part of the application process before it is made publicly available by the Centers for Medicare & Medicaid Services (CMS), unless CMS delays the implementation date.

CMS has announced that after June 30, 2007 NPI data will be made publicly available online in two formats: 1) a searchable registry (searchable only by provider name or NPI number); and 2) a downloadable data set (requiring technical expertise to download and access). Due to the Privacy Act, certain information will not be made available publicly. Data elements that will not be disclosed to the public are:

Social Security Numbers (SSN)
IRS Individual Taxpayer Identification Numbers (IRS ITIN)
Dates of Birth (DOB).

Certain data elements that were requested as part of the NPI application are considered “optional” and may be removed from the NPI data by providers without violating HIPAA regulations. Clinical social workers may be unaware that these data elements are optional and should consider whether to retain this information as part of their NPI data that will become publicly available. The optional elements include:

Provider “other name” information
Provider credential text
Business phone and fax information
Additional taxonomy codes (the primary taxonomy code is required)
Other provider identifier numbers or codes (e.g. “legacy” IDs)
Other provider identifier type code.

Clinical social workers should weigh privacy and security concerns with the need for disclosure of information to assist third-party payers to transition to the NPI system when deciding which optional data elements to retain in their NPI data file.

NPI application information that is not revised by June 30, 2007 may be disclosed by the National Plan and Provider Enumeration System (NPPES). CMS is determining whether to extend the period for the initial public release of the NPI data.

Clinical social workers and other providers may revise or update their NPI data at any time; however, to avoid any disclosure of the optional data elements social workers are urged to revise their NPI data by June 30, 2007. Three methods for updating NPI data are available:

If your application was submitted online, you must submit changes online at https://nppes.cms.hhs.gov/NPPES/StaticForward.do?forward=static.npistart
If your application was submitted on paper, call NPPES at 1-800-465-3203 and request a paper NPI update form, or download the revised NPI Application/Update Form (CMS-10114) from http://www.cms.hhs.gov/CMSForms/CMSForms/list.asp#TopOfPage.

Resources

CMS NPI Data Dissemination Information http://www.cms.hhs.gov/NationalProvIdentStand/06a_DataDissemination.asp#TopOfPage

Federal Register Notice Regarding NPI Data Dissemination: http://www.cms.hhs.gov/NationalProvIdentStand/Downloads/DataDisseminationNPI.pdf

Revised NPI Application Form (go to CMS Form 10114) http://www.cms.hhs.gov/CMSForms/CMSForms/list.asp#TopOfPage

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