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Before the



National Provider Identifier (NPI) Implementation

Presented by:

Britt Olander, Executive Director Planning and Specialty Contracting
Health Care Service Corporation
On behalf of the Blue Cross and Blue Shield Association

April 4, 2006



Good morning.  My name is Britt Olander and I am the Executive Director Planning and Specialty Contracting for Health Care Service Corporation (HCSC). HCSC is a non-investor owned mutual insurance company that operates through its Blue Cross and Blue Shield divisions in Illinois, Texas, New Mexico, and Oklahoma, and several subsidiaries to offer a variety of health and life insurance products and related services to employers and individuals. I am testifying on behalf of the Blue Cross and Blue Shield Association (BCBSA).  The Blue Cross and Blue Shield Association is made up of  38 independent, locally operated Blue Cross and Blue Shield companies that collectively provide healthcare coverage for 94 million (nearly one-in-three) Americans.

On behalf of the Blue Cross and Blue Shield Association, I would like to thank you for the opportunity to offer our comments on the subject of implementation of the National Provider Identifier (NPI).  My testimony – based on the experiences of other Blue Cross and Blue Shield Plans (“Plans”) as well as my own corporation – will raise these issues:

  • Successful implementation of the NPI by May 23, 2007 has been put at risk by the slower-than-expected rate of provider enumeration and the lack of specific requirements about data dissemination.
  • Plans that had been expecting to move soon into the critical testing phase are instead using up valuable time still building crosswalks and finalizing operational issues.
  • Although Plans are growing increasingly concerned about having enough time to do all the work at hand, Plans do not want to extend the implementation date, nor do they want to be forced into having costly contingency plans.  Instead, Plans want to work with CMS and other stakeholders to resolve the NPI problems expeditiously.

Slow Rate Of Provider Enumeration.

To date, the rate of provider enumeration and, therefore, the rate at which Plans receive NPIs, has been slower than expected.  Although hard statistics are not available, CMS’s latest enumeration report indicates that less than one-third of providers have been enumerated.   The proportion of providers who have been enumerated and who have supplied their NPIs to health plans is even lower.  While some Plans report that 30% or more of their participating providers have supplied NPIs, others report that the proportion supplying NPIs has been less than 2%.

Speeding up the rate of provider enumeration is essential to give payers sufficient time to validate provider NPIs, to build provider legacy crosswalks, and to conduct both the internal and trading partner testing necessary for a quality implementation.  Adequate time to do testing is particularly critical to the NPI implementation. Internal testing assures that Plans can input transactions with NPIs, accurately crosswalk NPIs to legacy numbers, accurately process the incoming transactions, accurately update internal systems, and accurately create outgoing transactions. Trading partner testing assures that both sides can process using the NPI without degrading either productivity or quality.

Three sets of problems appear to lie behind the slow rate of provider enumeration:

  • First, problems with the timing and content of subpart guidance. 

Confusion about subparts has contributed to providers’ delay in seeking NPIs.  Payers are uncertain what to recommend and providers are uncertain what to do.  Overcoming these problems will require clearer guidance so that payers and providers alike can take a common approach to enumerating subparts.  For example, CMS could provide guidelines that clarify how CMS will recognize those subparts not required by regulation that organizations establish for themselves.

  • Second, problems with the bulk enumeration process.

The bulk enumeration process is intended to ease the administrative burden of seeking NPIs for so-called Electronic File Interchange Organizations (EFIOs), which are mainly hospitals and large physician group practices.  Unfortunately, the availability of this process has slipped from Fall 2005 to (currently expected) late Spring of 2006.

Once the bulk enumeration process is operational, organizations can register as EFIOs and submit files containing individual provider’ applications to the NPPES.  However, EFIOs face a daunting task in taking the responsibility and the liability for enumerating their individual, non-employee providers.  Therefore, when the bulk enumeration process does begin, we recommend that CMS work closely with EFIOs providers to make the process understandable and accessible.

  • Third, a general lack of understanding of NPI requirements.

Many providers, particularly those in solo or small group practices, appear to lack information about the NPI, despite active provider outreach by health plans.  For example, Blue Cross and Blue Shield Plans have established communication channels to assist providers in (1) understanding the NPI rule, (2) learning how to obtain an NPI; and (3) following procedures to get the NPI into Plan records and files.  Still, more needs to be done across all of industry and the government to educate providers about NPI, in ways that are not too technical or confusing.

Lack of Specifics Related To Data Dissemination

In general, Plans expected to have their processing changes in place and crosswalks completed this year so that they could devote as much of the remaining time as possible to trading partner testing and implementation.  However, the lack of specific information about the NPPES dissemination process is causing project delays for the following reasons:

  • First, Plans were looking to the NPPES to serve as a trusted source to validate NPIs for individual providers.  But since Plans cannot yet access the NPPES, they must rely on slow, manual processes (such as requesting each provider’s registration documentation) to validate the NPI.
  • Second, Plans were looking to the NPPES to provide the data elements necessary – such as names, addresses, and other identifying characteristics – to build crosswalks.  But since Plans do not yet know which of the NPPES data elements will be distributed, Plans have had to build their crosswalks on the basis of assumptions.  If those assumptions are not correct, considerable rework will ensue.
  • Third, Plans were looking to the NPPES to provide information that could be used in provider directories and in the 834 enrollment transaction (e.g., for enrollees in HMOs to identify their primary care provider).  But since privacy policies for the NPPES are not available, Plans are unable to develop their business processes for provider directories and enrollment transactions.
  • Finally, Plans were looking to the NPPES to provide highly-automated access to providers’ files.  But since the process for making NPPES data available has not been defined, Plans are uncertain whether they will need to rely on manual procedures to download information.

The longer we go without specific information about the NPPES dissemination process, the more compressed the amount of time available for testing, and the greater the risk to successful project implementation.  Therefore, we urge CMS to provide dissemination requirements, policies, and procedures as soon as possible, to include allowing automated access to the NPPES data base without charges.


In conclusion, the primary concern of BCBS Plans is having enough time to complete this complex project, in particular sufficient time for testing.  We believe the recommendations we have offered will help industry achieve the NPI implementation date.  We are not seeking nor are we recommending that CMS grant an extension to the NPI implementation date.  But CMS and NPI’s stakeholders must be actively involved for the remainder of the implementation period to avoid any additional delays in enumerating providers.

I thank the subcommittee for the opportunity to discuss the NPI implementation project and will be happy to answer any questions you may have.