American Hospital Association logo

January 19, 2007

Simon P. Cohn, M.D., M.P.H., Chairman
Subcommittee on Standards and Security
National Committee on Vital and Health Statistics
200 Independence Avenue S.W.
Washington, DC 20201

Dear Chairman and Members of the Subcommittee on Standards and Security, NCVHS

The American Hospital Association (AHA) on behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, and our 37,000 individual members would like to express our concern with the upcoming implementation date for use of the National Provider Identifier (NPI).   It would be unwise to rely on exclusive use of the NPI beginning May 23, 2007.  There are numerous reasons why this date should be changed.  First and foremost, is to avoid serious disruption to existing revenue cycles and secondly, to avoid needless administrative tasks and costs associated with multiple re-testing.  This is especially important since not all of the components associated with NPI — namely the dissemination policy — are complete or operational.

The path toward exclusive use of the NPI involves a number of phases:  enumeration, implementation, and validation.   While much of the enumeration phase is nearly complete, more time is necessary for the implementation and validation phases.  These phases require careful coordination among vendors, clearinghouses, health plans, as well as access to the National Plan and Provider Enumeration System (NPPES) database.

We are now entering the implementation phase where providers are asked to submit their NPI along with their legacy numbers for purposes of testing.   Many providers are relying on their information systems vendors to help them carry both the NPI and legacy numbers during this phase.   There have, however, been delays by many of the systems vendors to make the necessary system changes to accommodate both the legacy identifier and the NPI.   In fact, we have heard that some vendors are not reworking their systems to accommodate both numbers and instead are planning on supporting either the legacy identifier or NPI, but not both.   Such actions complicate the testing and validation processes for the provider, clearinghouse, and health plan.

We are recommending the adoption of a contingency plan that extends the compliance date (for exclusive use of NPI) for at least 12 months after the May 23, 2007 deadline.  The contingency plan could go beyond 12 months if the NPI usage and processing levels do not meet an acceptable percentage.  It would be extremely helpful if health care understood that a contingency plan would soon be adopted and that clear guidance was issued on how the contingency phase would function.

The failure to issue a data dissemination policy for NPI last year has made the transition more difficult.   There is still the question of whether the policy will provide a workable framework that meets and supports the functions that hospitals have come to rely on similar to the Medicare UPIN database. Providers will need time to analyze the dissemination policy, design interfaces to the database, build the interface and test whether the interface provides timely solutions.   In short, all of these steps will require additional time for training and systems modifications.   In a hospital setting, this involves other important activities requiring coordination of identifier information such as admitting, handling referrals and orders for tests/services, fulfilling prescriptions, and transferring patients.    Billing is an important part of the current testing process, but it should be viewed as part of how providers, clearinghouses, and health plans will validate the information they exchange with one another and how they recognize a provider within their own files and how that provider information is contained in the NPPES.   This type of testing has yet to occur since the dissemination policy is not available.  Consequently testing that has already been undertaken will have to be performed once again when this NPPES information is made available.

The AHA is concerned that there is a rush to embrace a date simply because it is statutorily set without regard to the realities of readiness.   The focus should now be on where things currently stand, the changes that have, or have not, been made, and the steps that are needed to ameliorate any financial risk that would expose providers, and others from financial harm during the transition to NPI.   Therefore, we ask that at least a 12 month contingency plan be considered that would allow either the legacy or NPI (preferably both, if possible) as an acceptable identifier for reporting, We also ask for your assistance in urging the timely release before May 22, 2007 of the dissemination policy.  The AHA would recommend that the subcommittee review the progress made after ten months to determine whether additional time beyond the 12 months would be needed.

Thank you for your consideration, should you have any additional question you may contact me at 312-422-3398 or by email at .


George Arges
Senior Director
American Hospital Association