Going Public: CMS Sets June 28 Release Date for Providers' NPI Information
by Legal and Regulatory Affairs Staff
June 20, 2007 – The Centers for Medicare and Medicaid Services (CMS) recently published a notice in the Federal Register indicating that the agency plans to make some of the information that providers submitted in their NPI application available to the public beginning on June 28. The federal agency believes it has an obligation under the Freedom of Information Act to make this information publicly accessible, although this is the first time in the very long NPI process that the intention to make the information publicly available in this manner was made known.
The information that CMS plans to make available includes: your NPI; your name(s); your business location address, fax and phone; your business mailing address, fax and phone; your taxonomy code(s); your other provider identifier(s); your gender; the date you obtained your NPI; the date you last updated your NPI; and your license number. As described further below, some of this information is considered “optional” by CMS. You may exclude any “optional information” from your completed NPI application, and doing so by June 28 will prevent its public release by CMS.
Importantly, CMS will notrelease certain private information such as Social Security Numbers (SSN), Tax Identification Numbers, date of birth, or e-mail addresses. Some practitioners had expressed concern that CMS would release additional personal information, such as your home address. A home address was not requested as part of the NPI application, and so this information will not be released to the public.
The APA Practice Organization (APAPO) encourages members to review the information they submitted on their NPI application to make sure it is accurate. Practitioners who act now also have the opportunity to remove information from their NPI application that CMS considers “optional,’’ as described further below.
CMS’ current plan is to have a “Look Up” program on the Internet where people can type in a provider’s name and gain access to that provider’s NPI information. The Web location for this program had not been identified as of June 20. CMS also plans to make information available in a downloadable file, thereby allowing entities to download the entire NPI database. The agency expects both programs to be online as of June 28. After this date, CMS intends to make available monthly updates of the information in separate files.
Practitioners can check the accuracy of the NPI information currently stored under their name by going online to https://nppes.cms.hhs.gov/ and clicking on “National Provider Identifier.” If you applied for your NPI electronically, you would then click on “Login” to review and update your information as necessary, using the user ID and password you created when you applied. If you applied for your NPI using a paper form, you would begin by clicking on “Create Login to View or Update Your NPI Data.”
In the process of checking your NPI application for accuracy, be advised that a CMS representative has informed us that many providers inadvertently put their SSN in fields other than the field for this number. Practitioners should ensure that their SSN appears only in the field requesting the SSN since this field will not be released to the public. Further, the NPI application requests only your business address, not your home address, so you may want to make sure that you did not inadvertently include your home address on the application.
In addition to ensuring that their NPI information is accurate, providers may remove information they included on their NPI application that CMS considers “optional” (see list below). Anyone who wishes to remove certain of the optional information listed below must do so by June 28 because this information is expected to be made public on that date.
The APAPO has urged CMS to delay this deadline. The short notice period afforded by CMS makes it unrealistic for millions of providers to learn about this policy and to have an opportunity to update their information. Further, important details governing implementation of this new policy have not been clarified. For example, the agency has not yet published a complete list of the optional items that providers may remove from the NPI database.
CMS has informed us that they are currently working on extending the June 28 deadline to give providers more time to review their NPI information. The agency will announce any extension on their NPI website: http://www.cms.hhs.gov/NationalProvIdentStand/.
In speaking with CMS representatives, we have learned that the items below as listed on the NPI application are the ones considered “optional” thus far:
· Other last, first and middle name (if you listed more than one name)
· Prefix, suffix, and credential
· Fax and phonenumbers in the business mailing address category
· Fax number in the business location category
· All but one taxonomy code
· Other provider identifiers
· Other provider identifier type code
The APAPO offers the following considerations when reviewing your optional NPI information:
· The provider identifier field, which reflects the identification numbers assigned to you by payers prior to the NPI, was included to make it easier for payers to link you to your NPI number. Including this information in the NPI database should reduce the chance of payment delays. If, however, your provider identifier was your Social Security Number, we recommend that you remove it, since a Social Security Number in this field would not be protected from public release. Further, some psychologists may have included their DEA number in the provider identifier field. Because providers are not required to submit their DEA, and including this number is unlikely to assist with payment, we recommend that you remove your DEA if applicable to reduce any chance of fraudulent use.
· If you specifically decided to choose more than one taxonomy code (providers must select at least one taxonomy code), there is no reason to delete your taxonomy code information.
We will monitor the NPI information release closely during the initial phases of implementation to determine if it creates difficulties for psychologists. For example, the public availability of NPI information might make it easier for marketers to mail information to your business address. If we find that it does create problems, we will take appropriate action with CMS. Please assist us with the monitoring process by letting us know if you experience problems. You may send an email to our legal and regulatory affairs staff at praclegal@apa.org or call them at 202-336-5886.
The APA Practice Organization will continue to advise members of NPI-related developments in future issues of PracticeUpdate and other communications. 
CMS-NPI.final.pdf
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