January 24, 2007

Karen Raines
Assistant Vice President

Thank you.  Mr. Chairman and members of the Standards and Security Subcommittee, my name is Karen Raines, Assistant Vice President of Regulatory Compliance Support for HCA and I am providing testimony today on the behalf of the Federation of American Hospitals.  The Federation is the national representative of privately owned or managed community hospitals and health systems throughout the United States.  We appreciate the opportunity to provide comment on the National Provider Identifier, or NPI.  Also of note, I am a member of the National Uniform Billing Committee, also representing the Federation.

At HCA, our focus and attention to the NPI began first quarter 2004 immediately following the January 23rd release from HHS of the NPI Final Rule. We immediately developed a project team and an infrastructure at our corporate office to ensure consistency with the way in which our hospitals, freestanding ambulatory surgery, imaging and radiology oncology centers, and physician practices would be enumerated, how we would address training and education, system remediation, and the other aspects involved in implementing and operationalizing the NPI.  We developed extensive toolkits and other aids for our providers, an extensive series of ongoing written communications and updates to keep them abreast of both our activities internal to the company, but also with the industry and at large. We’re in the process of completing extensive internal system remediation to accommodate the NPI, and are continuing to work very closely with our external billing vendors and clearinghouses to ensure a timely and compliant NPI implementation.   While HCA currently owns approx. 180 hospitals, we have to-date applied for approx 700 hospital NPIs.  While we understand the intent of the NPI Final Rule and the value of hospitals having a single NPI, due to the complexities associated with how many hospitals are structured with distinct subparts, or specialty units, and the uncertainty communicated to us by health plans as to what their expectations or requirements would be regarding the NPI, for the most part we enumerated our hospitals based on how their legacy provider numbers are currently assigned.    Relative to enumeration, our focus was on proactively eliminating as much potential risk as possible and ensuring not only that we would be paid timely, but that the payment would be accurate based on the correct payment rates or payment methodologies used by the payer for the specific type of clinical service provided to our patients.  For example, in addition to providing acute inpatient hospital services, many of our hospitals have psych, rehab, skilled nursing and/or swing bed specialty units or subparts.  From a payer’s perspective, there are a variety of different payment methodologies used by the payer to accurately process and adjudicate various types of claims.  By billing all of those services under the same global NPI, we were not able to obtain the information needed from payers to ensure the receipt of a prompt and correct payment, particularly since we were not successful in getting payers to confirm that they would be willing to look at the other data on the claim to determine how to properly adjudicate the claim.   By approaching enumeration from this perspective, we collapsed approx. 2000 hospital legacy provider numbers into the approx. 700 NPIs. While we clearly aren’t at one per hospital, we have significantly reduced the number of legacy provider numbers we currently are required to report.   We found Fox Systems, the NPI Enumerator, extremely helpful and responsive in meeting our needs.  For example, many of our hospitals today have in excess of 20 payer specific legacy providers numbers and while the electronic NPI application process limits a hospital to providing up to 20 legacy numbers, we successfully implemented a process with Fox that allowed us still apply electronically, but to provide them with the additional ‘overflow’ numbers which gave us a greater sense of confidence that those additional legacy numbers would be housed within the National Plan and Provider Enumeration System, or NPPES.

We’re currently now in the process of notifying all our third party payers, both federally and non-federally funded, of the NPIs that we have obtained and to discuss how we can collaborate together to ensure that thorough testing of both the claim and remittance advice occurs.  While we’ve had limited success to-date in findings health plans that will be willing to test, but we believe that successful testing of electronic transactions containing NPIs is critical to a successful implementation.

Relative to the NPI confirmations obtained from the enumerator, many of our third-party payers are requesting hard copies of the NPI acknowledgements we’ve received, so there’s been an additional need for providers to develop and implement a process to support each of the unique requests received from payers.  We’ve experienced many variances with the way in which these health plans are approaching the NPI and the requirements they are placing on providers.  Some payers are allowing the NPIs to be reported in bulk on electronic spreadsheets, some are requiring hard copies of the confirmations be mailed and/or faxed, some want them registered on their own internal web sites, and even though we’re a short number of months away from the May 2007 compliance date, some payers are still not able to provide any direction to hospitals as to what their expectations, recommendations, or requirements will be.  The most conversative approach and the one we believe does the most to mitigate potential risk is to provide each payer with all NPIs and to follow-up with a copy of the confirmation letter from the NPPES, if requested.

Which brings me to an area of vital concern that I would like to discuss.   NPI Dissemination.  While we understand the NPI dissemination notice is in internal final clearance within CMS, we believe that the timeline associated with the release of the notice or policy is critical to the successful implementation of the NPI.  Again, from an HCA perspective, we have been informed by some private payers that they are basing how they will implement the NPI on the sole assumption that they will have access to the NPPES and that this access will allow them to successfully map or crosswalk the NPI contained within the electronic transaction back to the legacy or unique payer specific identifier which they currently have issued.  From a hospital’s perspective, since we not only have to report our facility NPI on the claim, but the NPIs for each of the attending, surgical, rendering, referring, or other physician, it is critical that we also be granted access to the NPPES so that we can obtain those physician NPIs in a similar way to the manner in which we retrieve physician UPINs today to allow us to submit a compliant and timely hospital claim form.  We are currently are in the process of individually contacting over 400,000 physicians which have admitting, surgical and other privileges within our hospitals, but are also concerned with the physicians which we don’t otherwise have a relationship with but who refer patients to our hospitals for outpatient services and how we will be able to successfully obtain their NPIs.  Without access to the NPPES, providers should potentially expect to incur a delay in claim submission and cash flow while they stop to manually obtain these physician NPIs from their offices.  Given that we are now into 2007, industry access to the data in the NPPES system is one of the most critical aspects needed to successfully achieve NPI compliance both from a May 2007 implementation, as well as being a critical component from an on-going support perspective.

Again, I would like to thank you on the behalf of the Federation of American Hospitals for the opportunity to present this testimony, and will glad to respond later in the session to any questions or points of clarification you might have.