NPI and Facilities

[jschmor]

It has been my experience that many contracts and pricing tables are NOT consistently linked by NPI for facilities. Many times for facilities the CMS Certification Number (CCN) (legacy name OSCAR) is the unique facility ID for Inpatient, Outpatient, and ASC facilities. Is anyone else experiencing this issue with facilities and is it something that might be worth considering as an ID to capture for institutional types?

Source of the CCN ids:
https://data.cms.gov/provider-characteristics/hospitals-and-other-facilities/provider-of-services-file-hospital-non-hospital-facilities

[ryan-thomas-peterson]

For institutional claims, we have the same experience @jschmor. Contracts we have are often written at the TIN level and not maintained for every office site. Entity type 2 NPIs (facilities instead of practitioners) are not cleanly defined. CMS guidance is that each subpart of an organization may designate their own NPI, but what a subpart is more loosely defined (https://www.cms.gov/Regulations-and-Guidance/Administrative-Simplification/NationalProvIdentStand/Downloads/npi_fs_subparts_032106.pdf). We have found NPIs and subparts for facilities come and go and for many contracts we don't actively maintain this level of granularity for contract implementation.

For institutional billing types, what should be listed in the provider array? Should it be the entity type 2 NPIs? If so, can documentation be updated?

If contracts do not require designation of an NPI what other approaches are people considering?

[BonHadVan]

Since NPI is a required element in the schema our understanding is that it cannot be empty. We intended to report the Type 2 NPI's in the array for our Facility providers which appears in conflict with the 'definition' however there appears to be no editing that will prevent us from doing this. CMS should provide clarity on the expectations for the NPI for Facility and Ancillary providers that don't have Type 1 NPI's.

[taylorpatriciab]

@shaselton-usds Could clarity on the expectations on populating the NPI for Facility and Ancillary providers that don't have a Type 1 NPI be provided?

[skochin]

I believe there is still a need for guidance on identifying facilities in the files - as mentioned, Type 1 NPIs can only be held by people, and we'd be missing (or obscuring) a significant part of the transparency equation if we don't identify rates paid to hospitals, ambulatory surgical centers, independent laboratories, and such. @shaselton-usds is there an update on this?

[BonHadVan]

@shaselton-usds - Could you please clarify expectations for NPI when the provider is a Facility that only has a Type '2' NPI? Should no NPI be sent? Or should the Type 2 NPI be sent?

https://github.com/CMSgov/price-transparency-guide/tree/master/schemas/in-network-rates#providers-object

[shaselton-usds]

There is a PR that updates the documentation to clarify in the allowance of NPI Type 2 reporting here: #446

[tdfow]

I am not seeing any reference to any 'Types of NPI' in the mandate. Where in the mandate does it specify the type of NPI that should only be used? It seems to only mention that NPI is required for the information being published. https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/CMS-Transparency-in-Coverage-9915F.pdf

[skochin]

I believe you're correct, I have not found that specification in the rules either. NPI is a required data element for all providers, so it doesn't seem to make sense to limit the type of NPI used,

[ryan-thomas-peterson]

@tdfow the schema description under in-network rates in the Readme.md lists the following for npi under the provider object: "An array of individual (type 1) provider identification numbers (NPI).". That was part of my initial confusion above that remains.

[rakeshkatte]

Since there is no mention of the type of NPI we are not differentiating between the NPIs.

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On Wed, 30 Mar 2022, 02:20 skochin, ***@***.***> wrote: I believe you're correct, I have not found that specification in the rules either. NPI is a required data element for all providers, so it doesn't seem to make sense to limit the type of NPI used, — Reply to this email directly, view it on GitHub <#273 (reply in thread)>, or unsubscribe <https://github.com/notifications/unsubscribe-auth/AIJ2FFMGZ7UCXASU7GN2AXDVCNUJDANCNFSM5HWKI2GA> . You are receiving this because you are subscribed to this thread.Message ID: <CMSgov/price-transparency-guide/repo-discussions/273/comments/2464954 @github.com>

[shaselton-usds]

Updated the documentation to clarify the allowance of using NPI type 2s in reporting: #446. Thanks for the patience: