by Legal and Regulatory Affairs Staff

Editor’s Note: This article has been updated from the original version that appeared in the PracticeUpdate E-Newsletteron July 7, 2005.

Updated July 15, 2005 -- In late May 2005, the U.S. Department of Health and Human Services (HHS) began the process of assigning a unique identification number known as a National Provider Identifier (NPI) to each health professional or entity that enrolls for the standard 10-digit identifier. Practitioners who want or need to apply for an NPI have until May 23, 2007 to do so.

Representatives from the Practice Organization have been in touch with a representative from CMS to discuss the NPI and have obtained clarification on the NPI.

Who Is Required to Obtain an NPI
All health care providers -- individuals as well as organizations -- are eligible for an NPI. All “covered entities” under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), consisting of health care professionals and entities that trigger HIPAA, are required to obtain an NPI.

Where the NPI Originated and Its Stated Goal
HIPAA mandated implementation of the NPI. According to HHS, the goal is to improve the efficiency of the health care industry in general and federal health care programs in particular. According to HHS, the use of a single identifier is intended to enable the efficient electronic transmission of health care information.

In the past, health care professionals have used a variety of identifiers such as their tax ID number or Social Security Number for federal health program enrollment and other purposes. According to HHS, these various sources of identifiers have led to disorganization and confusion in health care operations and reimbursement. This is especially true insofar as some identifiers have been used for more than one individual -- for example, when an identifier assigned to a facility or institution applies to numerous health care professionals who are associated with that facility.

Application Process
Information about the NPI and the application process appears on the HHS website. The form to use to enroll in the program is located on the HHS site as well. The NPI form is CMS number 10114.

An NPI will be assigned to a health care professional once he or she successfully completes the finalized NPI application. A private entity known as the National Provider System, or the “Enumerator,” will process all NPI applications. Any health care professional with changes to information related to his or her NPI, such as address or phone number, will need to provide updated information to the Enumerator within 30 days of the change. The Department of Health and Human Services has contracted with Fox Systems, Inc. to act as the enumerator in the NPI process. Information on the enumerator is located on the HHS website.

Taxonomy Codes
In applying for an NPI, providers will be asked to pick a “taxonomy code.” These codes are alphanumeric codes corresponding to various health care practice descriptions. A committee known as the National Uniform Claim Committee (NUCC) creates, updates and maintains these taxonomy codes, including codes that pertain to psychologists.

HHS has described the purpose of the codes as helping to distinguish between health professionals, for example, Mary Smith the psychologist versus Mary Smith the oncologist. The taxonomy codes include two main categories for psychologists – psychology and neuropsychology. Within the broader categories, there are codes for subcategories such as: addiction; child, youth and family; and forensic psychology. In discussions with CMS, the Practice Organization was told that psychologists can list up to 15 taxonomy codes, if necessary, on their enrollment forms to describe their practices. Also, the CMS representative stated that these taxonomy codes will not be used by the federal healthcare programs for billing purposes. Rather, as stated they will be used to have a greater ability to identify and distinguish between providers.

The full listing and definitions for the taxonomy codes are not yet complete, making it difficult for psychologists to determine the appropriate codes to use on their NPI application. For example, the agency has designated “clinical psychology” among the subcategories of taxonomy codes, rather than as one of the broader categories. We are exploring with HHS officials the rationale for this decision. Since the taxonomy codes for psychology are not yet complete, it may be reasonable for you to wait to enroll in the NPI program until the codes have been finalized. The APA Practice Directorate is working to provide updated and accurate information to the NUCC in order for them to correct and enhance the taxonomy codes already available to psychologists. We expect that these codes will be updated by mid 2006 – still leaving our members ample time to enroll in the NPI program prior to the May 23, 2007 deadline.

The codes that have been identified so far can be located on the Washington Publishing Company website.

Look for updates about the NPI at APApractice.org, including future issues of the PracticeUpdate E-Newsletter. For more information, contact Legal and Regulatory Affairs Staff at 202-336-5886.