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NPI: More Than Just a Number

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Billing and Reimbursement are dependent on the taxonomy code designation and detail

OLYMPUS DIGITAL CAMERA

By Susan Theuns, PA-C, CPC, CHC

“Taxonomy codes and other elements of NPI registration directly affect a provider’s ability to submit claims, order services, and receive reimbursement.”

Back when the National Provider Identifier (NPI) was implemented in 2005 as part of the Health Insurance Portability and Accountability Act (HIPAA), a new identifier accompanied it: the taxonomy code. With that, the Centers for Medicare & Medicaid Services (CMS) developed the National Plan and Provider Enumeration System (NPPES) to officially assign these unique identifiers of the provider. These codes were created to improve the efficiencies and effectiveness of electronic medical claims submission and electronic health information.

What’s in a Name?

When registering for an NPI, one of the elements that also needs to be completed is the selection of a taxonomy code. Taxonomy codes are nationally standardized 10-character codes that are alphanumeric. The definitions range from prosthesis case managers to transplant surgeons. When healthcare providers initially applied for an NPI number, little importance was associated with selection of the taxonomy codes. However, now payers, including Medicare and Medicaid, are rejecting claims based on inconsistency of services provided and taxonomy codes. Now it matters.

The Healthcare Provider Taxonomy Code Set is available from the Washington Publishing Company (WPC) at wpc-edi.com. Taxonomy codes are maintained by the National Uniform Claim Committee, nucc.org, and update twice yearly with effective dates for changes April first and October first. Information included with the hierarchical classifications include descriptions and definitions as well as the codes themselves. The codes can be a primary (level I classification) or subclassifications (level II and III). The more detailed a classification, the more specialized the description. These are the codes that determine a provider’s area of concentration within their discipline, so being generic is not as effectual as drilling down to the most specific code. Think of this as an unspecified versus a specified code.

Depending on the underlying area of expertise, there may be more than one taxonomy code to choose from. For example, a “hand surgeon” may be subclassified under orthopaedics or plastic surgery – depending on the physician’s training. Sports Medicine is another example: there are 8 different taxonomy codes for this specialty under Emergency Medicine, Family Medicine, Internal Medicine, Orthopaedics, Pediatrics, Physical Medicine & Rehabilitation, Psychiatry & Neurology and even Chiropractic. By definition, selection of the code does not require board certification per se; but it does require special education, training, experience and knowledge in the selected area. Therefore, it is important to carefully select any subclassification from the correct and most accurate level I classification.

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Case Studies: Taxonomy Errors that Affect Reimbursement and Functionality

As healthcare becomes more technologically integrated, accuracy in electronic claims submission data becomes critical to reimbursement. In today’s world, a slight variation can make the difference between full payment and denial. Because a provider’s taxonomy code resides in the NPI registry, it has a direct relationship to payer credentialing. The taxonomy code identifies any specialty or sub-specialty that a provider has. Examples of taxonomy errors and necessary updates are (1) when a resident or fellow graduates and becomes a board-certified or state licensed physician, (2) a provider obtains specialty credentials i.e. orthopaedist becomes a trauma, hand or spine specialist, primary care provider becomes a geriatrics or palliative care specialist or hospitalist, and so forth. There are numerous sub-specialties available nowadays that impact when a physician can act in a consultant role from a billing perspective.

Here are some case scenarios that can result in non-payment or lack of services:

  1. A registered nurse (RN) completed advanced training and is now a licensed Certified Registered Nurse Practitioner (CRNP). She worked in this role for several years before being told by a patient that the prescription she had given her for diabetes supplies was denied by the pharmacy. Upon researching the root cause of the denial, it was discovered that the CRNP had never updated her taxonomy code from RN to CRNP in the NPPES database. Only a healthcare provider can order Durable Medical Equipment (DME) and supplies for a patient.
  2. A general orthopaedist saw a patient in the office and asked a colleague with more specialized training to see the patient with him when faced with a complex orthopaedic problem. Both physicians (they had the same employer and billed under the same group NPI), tried to bill an evaluation and management code for the services they rendered. One claim was paid and one claim was denied as a duplicate service. Research revealed that although one physician specialized in trauma and the other in foot and ankle, both used the generic taxonomy code of 207X00000X. Had they each selected a more detailed code, they both would have been eligible to receive reimbursement for the services they rendered on the same patient, same day.

See Figure: 1

A geriatrics specialist consulted on numerous hospital patients at the request of the admitting hospitalist, an internist. All of the Medicare Part B claims and some commercial claims were denied for these hospitalized patients and the geriatrician could not understand why. Investigation of the claims showed duplicate claims for internal medicine subsequent hospital care, no designation of attending of record, and care denied as non-participating under specialty contracts. All of these situations resulted from the provider never updating his taxonomy code from Internal Medicine to Geriatric Medicine when he passed his boards 7 years prior. Even the specialty contract recognized him as primary care and disallowed his consults. In addition, the hospitalist had never updated his taxonomy code from “internist” to “hospitalist”, which added another aspect of billing inaccuracy to his claims.

  • A new graduate took a job as a hospitalist and was fully credentialed upon hire, several months after completing her residency program. As a “student” in a residency program, she had applied for her NPI and correctly selected taxonomy code 390200000X.

See Figure: 2

However, she neglected to update her taxonomy code to “hospitalist” as the primary designation and “internal medicine” as the secondary when she graduated and took the new job. This resulted in rejections and denials deeming her as ineligible to provide billable services.

  • A physician received an inquiry from state Medicaid questioning whether or not he was a sole proprietor or not. They were holding claims awaiting his response. A quick check of his NPI profile showed that it had not been updated since 2007, at which time he had indicated that he was a sole proprietor. Since his initial NPI application, he had become employed by a medical group and was billing under his individual NPI and group NPI. Once he accessed the portal and changed the response to sole proprietor to “no”, the credentialing issue with Medicaid was resolved.
  • Working the rejection and denial billing reports, a director noted a pattern in the rejections from various payors for one physician stating that the provider was not eligible to provide that type of service. Careful inspection revealed an outdated and incorrect taxonomy code on the provider NPI profile that was inconsistent with the services being provided.

See Figure: 3

With all of these issues, the providers technically have 30 days to notify NPPES of any changes. Not adhering to this guideline is a self-imposed penalty that exceeds any potential fines from NPPES since reimbursement can be negatively affected. Most likely because of the reimbursement consequences, NPPES rarely imposes fines for delayed updates to a provider NPI, although they maintain the right under federal guidelines.

Figures: Figures 1 2 3

Assessment

This critical information should be carefully reviewed upon hire and annually to ensure accuracy in reporting and billing. New taxonomy codes are added bi-annually so new sub-specialties may become available that would allow a healthcare provider to be more specific than previously. In addition, providers of all levels should be encouraged to be part of the process.

An NPI is a provider’s for life and is not dependent upon employer so they need to be engaged and part of the process. Most of the information on the NPPES website is accessible by the public. This means that if a provider puts a home address or home phone/cell phone number for contact, their patients now have access to this information. It is a best practice to use only business contact addresses and phone numbers for your NPI for this reason.

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9.13 NPI Logo and Business Card Gelling Ideas 24

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Summary

Taxonomy codes and other elements of NPI registration directly affect a provider’s ability to submit claims, order services, and receive reimbursement. This often overlooked and neglected piece of a provider’s NPI warrants regular review and updating when any changes occur, such as name change, office move, board certification, change in role, or shift in the specialty-focus of a practice, despite official certification. Last, but not least, the provider user name and password for NPPES and the NPI database are the same for the Provider Enrollment, Chain and Ownership System (PECOS), CMS Analysis & Information (A&I), and the EHR Incentives Program portal to report Meaningful Use and PQRS. As with all user names and passwords, they need to be maintained but carefully protected. It will save a lot of headaches for those who rely on these on-line service portals for their livelihood.

References

CMS Center for Program Integrity, Medicare Provider/Supplier to Healthcare Provider Taxonomy Crosswalk, November 2015.

National Plan and Provider Enumeration System, https://nppes.cms.hhs.gov/NPPES/Welcome.do

Washington Publishing Company, Health Care Provider Taxonomy Code Set, http://www.wpc-edi.com/reference/

ABOUT:

Susan Theuns, PA-C, CPC, CHC, is the administrative director of physician practices at MedStar Union Memorial Hospital in Baltimore, Maryland. In addition to her certifications, she holds degrees in Allied Health, Business Management and Leadership & Education. Theuns serves as a national advisor and is a contributing author for The Business of Medical Practice, 3rd edition. She is a member of the Baltimore, Maryland, local chapter.

Conclusion

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Speaker: If you need a moderator or speaker for an upcoming event, Dr. David E. Marcinko; MBA – Publisher-in-Chief of the Medical Executive-Post – is available for seminar or speaking engagements. Contact: MarcinkoAdvisors@msn.com

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BoMP-3rd

http://www.BusinessofMedicalPractice.com

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More on Risk Aversion

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Erik Hare

[By Erik Hare]

The Global Economic Slowdown

The economic news out of most of the world points to a continued, if not new, slowdown. Japan is going nowhere, Europe may be shrinking, China is bleeding capital, and the rest of the world is hang…

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coffee

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Risk Aversion

Conclusion

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Speaker: If you need a moderator or speaker for an upcoming event, Dr. David E. Marcinko; MBA – Publisher-in-Chief of the Medical Executive-Post – is available for seminar or speaking engagements. Contact: MarcinkoAdvisors@msn.com

OUR OTHER PRINT BOOKS AND RELATED INFORMATION SOURCES:

 Risk Management, Liability Insurance, and Asset Protection Strategies for Doctors and Advisors: Best Practices from Leading Consultants and Certified Medical Planners™

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On Corporate Taxes

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Erik Hare

[By Erik Hare]

What is a fair corporate tax?

It’s a hot political topic, but one loaded with a tremendous amount of mis-information. On the left, it’s common to cite “loopholes” which allow corporations to “offsh…

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pc

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Corporate Taxes

Conclusion

Your thoughts and comments on this ME-P are appreciated. Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

Speaker: If you need a moderator or speaker for an upcoming event, Dr. David E. Marcinko; MBA – Publisher-in-Chief of the Medical Executive-Post – is available for seminar or speaking engagements. Contact: MarcinkoAdvisors@msn.com

OUR OTHER PRINT BOOKS AND RELATED INFORMATION SOURCES:

Risk Management, Liability Insurance, and Asset Protection Strategies for Doctors and Advisors: Best Practices from Leading Consultants and Certified Medical Planners™8Comprehensive Financial Planning Strategies for Doctors and Advisors: Best Practices from Leading Consultants and Certified Medical Planners™

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PHI RansomWare Just Went Up!

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1-darrellpruitt

[By Darrell K. Pruitt DDS]

Expect malware entrepreneurs to charge what the market will bear, again and again.

“OCR Releases Guidance on Ransomware: ‘Your Money or Your PHI’”. By Dianne J. Bourque for The National Law Review,” July 12, 2016

http://www.natlawreview.com/article/ocr-releases-guidance-ransomware-your-money-or-your-phi

Bourque: “A key component of the guidance provides a ransomware attack that encrypts a Covered Entity’s ePHI is presumed to be a breach. As ransomware can infect a Covered Entity’s entire system, this presumption may lead to enormous breach notification obligations.”

Bourque adds: “OCR indicates that when ePHI is encrypted as a result of a ransomware attack, a breach has occurred because the ePHI encrypted by the ransomware was acquired (i.e., unauthorized individuals took possession of the information) and is thus a ‘disclosure’ not permitted under the HIPAA Privacy Rule has occurred.”

When patients are notified of data breaches – for any reason – many will quietly change providers. According to The Ponemon Institute, loss of future income is the most costly result of lawfully reporting data breaches…. and ransomware attacks are at “epidemic” levels. I have heard dentists are paying the ransom quickly.

The disincentives to do the right thing were overwhelming providers even before the OCR’s recent ruling. Such is the ugly nature of extortion.

Assessment

Cha-ching! 

Conclusion

Your thoughts and comments on this ME-P are appreciated. Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

Speaker: If you need a moderator or speaker for an upcoming event, Dr. David E. Marcinko; MBA – Publisher-in-Chief of the Medical Executive-Post – is available for seminar or speaking engagements. Contact: MarcinkoAdvisors@msn.com

OUR OTHER PRINT BOOKS AND RELATED INFORMATION SOURCES:

Risk Management, Liability Insurance, and Asset Protection Strategies for Doctors and Advisors: Best Practices from Leading Consultants and Certified Medical Planners™

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Marriage – The Second Time Around

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Or … Third Time Around!

th

By Dan Timotic CFA
[Managing Principal]

Roughly four in 10 new marriages in 2013 included at least one partner who had been married before, and altogether about 42 million Americans have been married more than once [1].

A second marriage can create numerous estate planning challenges, especially when you wish to provide for both your current spouse and your children from a previous marriage. If you remarry later in life, your spouse and your adult children may not develop a close relationship, which could complicate matters when you die.

With a traditional family, estate assets are often inherited by the surviving spouse and eventually passed down to the couple’s children. Blended families, however, may require a more detailed strategy.

Start by having an honest conversation with your spouse (or fiancée) about your separate and shared finances and goals for the future.

Think Ahead

A prenuptial agreement is a written contract between prospective spouses that states how assets will be owned and distributed during the marriage, in the event of divorce, and at death. Each spouse’s financial rights and responsibilities are predetermined and clearly spelled out, and the contract can be altered or broken only with the consent of both parties.

Prenuptial agreements are not for everyone, but they could help reduce conflict between a surviving spouse, your adult children, and other family members.

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heart

[Broken Heart]

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Useful Trusts

Placing assets in a properly structured living trust makes it more difficult for someone to contest your will and also avoids probate. The assets would be available to your heirs more quickly, and your private information would be kept out of the public domain.

A qualified terminable interest property (QTIP) trust is a marital trust typically used in conjunction with a bypass trust. When you die, your spouse receives a lifelong income from the assets in the trust. After your surviving spouse dies, the remaining trust assets are distributed to your children, or other designated heirs, according to your specific instructions.

A QTIP trust might be a viable option if you’re certain that a permanent financial relationship between your spouse and adult children will not be a constant source of tension and frustration. If you are uncomfortable making your children wait until your spouse’s death to receive an inheritance, it might make more sense to eliminate the financial connection between your surviving spouse and your children.

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[Divorce Decree]

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Pick Your Approach

One common arrangement is simply to designate a specific percentage of estate assets to be distributed outright for the spouse, each child, and any other heirs. This way, everyone shares in the appreciation or depreciation of the assets.

Another method involves allocating assets to various heirs based on specific financial needs or benefits. For example, a surviving spouse might inherit the home and retirement accounts, while the children might receive other financial assets such as shares of a business, family heirlooms, or the proceeds of a life insurance policy.

The beneficiary designations on all your retirement accounts, brokerage accounts, and insurance policies should also be updated and consistent with your overall estate plan. If your children are adults, you may want to keep them informed about your decisions so that everyone knows what to expect.

Assessment

Remember – Trusts incur up-front costs, often have ongoing administrative fees, and involve complex tax rules and regulations. You should consider the counsel of an experienced estate planning professional and your legal and tax advisors before implementing a trust strategy.

Citation: Pew Research Center, 2014

Conclusion

Your thoughts and comments on this ME-P are appreciated. Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

Speaker: If you need a moderator or speaker for an upcoming event, Dr. David E. Marcinko; MBA – Publisher-in-Chief of the Medical Executive-Post – is available for seminar or speaking engagements. Contact: MarcinkoAdvisors@msn.com

OUR OTHER PRINT BOOKS AND RELATED INFORMATION SOURCES:

 Risk Management, Liability Insurance, and Asset Protection Strategies for Doctors and Advisors: Best Practices from Leading Consultants and Certified Medical Planners™8Comprehensive Financial Planning Strategies for Doctors and Advisors: Best Practices from Leading Consultants and Certified Medical Planners™

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What to Expect for ACA Premiums?

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An Actuary Opens the Black Box

This essay looks at the factors involved in setting premiums for health plans offered on the health insurance exchanges [HIEs].

vaccine+blue

NIHCM – What to Expect for 2015 ACA Premiums: An Actuary Opens the Black Box

Assessment

So, were the actuaries correct?

Conclusion

Your thoughts and comments on this ME-P are appreciated. Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

Speaker: If you need a moderator or speaker for an upcoming event, Dr. David E. Marcinko; MBA – Publisher-in-Chief of the Medical Executive-Post – is available for seminar or speaking engagements. Contact: MarcinkoAdvisors@msn.com

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Product DetailsProduct Details

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Two New Books VITAL to Doctor’s Succes!

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PHYSICIAN FOCUSED FINANCIAL PLANNING AND RISK MANAGEMENT COMPANION TEXTBOOK SET

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 Risk Management, Liability Insurance, and Asset Protection Strategies for Doctors and Advisors: Best Practices from Leading Consultants and Certified Medical Planners™           Comprehensive Financial Planning Strategies for Doctors and Advisors: Best Practices from Leading Consultants and Certified Medical Planners™

[Dr. Cappiello PhD MBA] *** [Foreword Dr. Krieger MD MBA]

Front Matter with Foreword by Jason Dyken MD MBA

Enter the CMPs

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