LOS ANGELES COUNTY
DEPARTMENT OF MENTAL HEALTH
  Policy 106.14 National Provider Identifier Requirements
 
  PROCEDURES
  1. Los Angeles County Department of Mental Health (DMH/Department) Employees (hired prior to May 23, 2008) 
     
    1. Each DMH employee or other workforce member who is a rendering provider (clinician) or provides direct billable services is required to have a Type 1 National Provider Identifier (NPI). As of April 16, 2008, this includes employees who claim only Community Outreach Services.
       
    2. DMH employees shall follow Instructions for Applying for an NPI.
       
    3. DMH employees will provide a copy of his/her NPI notification to the Compliance Program Office.
       
    4. After November 15, 2006, new hires shall submit his/her NPI information to Chief Information Office (CIO) on a Rendering Provider Form.  

      NOTE: The National Plan and Provider Enumeration System (NPPES) does not recognize an effective date for the NPI. The date to use in completing the Rendering Provider Form is the date of the NPI notification. A copy of the NPI Notification should accompany the Rendering Provider Form.
       
    5. DMH employees are responsible for updating his/her NPI data submitted to NPPES within 30 calendar days of any change(s). Effective January 23, 2005, updating NPI data is a Health Insurance Portability and Accountability Act (HIPAA) requirement. (45 CFR Part 162).
       
    6. Failure to provide an NPI within 30 days of employment will be cause for rejection of a request for employment and/or will be cause for termination of employment with DMH.
       
  2. New Employees (hired after May 23, 2008)
     
    1. It is the responsibility of the hiring manager to identify employees who will be required to have an NPI. 
       
    2. If the employee requires an NPI, the hiring manager will send the prospective employee a Letter of Instruction to New Hire re: NPI indicating that the employee will need to submit proof of their NPI within 30 days of his/her hire date to Human Resources. Enclosed with the letter will be a copy of the Rendering Provider Form and Instructions for Applying for an NPI. 
       
    3. A copy of the letter will be forwarded to the DMH Human Resources Bureau (DMH-HRB). This copy will be used to determine who is required to provide an NPI. DMH-HRB will be responsible for ensuring the employee has an NPI within 30 days of his/her hire date, thus ensuring timely claiming to federal and State programs.
       
    4. Upon receipt of the letter, the new hire will:
       
      1. Apply for an NPI if necessary.
         
      2. If the new hire has an NPI, gather documentation of proof of his/her NPI.
         
      3. Complete the Rendering Provider Form. The manager will be responsible for advising the employee of the various codes to be included on the form, as well as ensuring the accuracy of these codes.
         
    5. On the first day of employment, the new hire should provide a copy of his/her NPI documentation and the Rendering Provider Form to his/her supervisor. The supervisor will review the Rendering Provider Form ensuring that it is completed properly and that the NPI on the form matches the NPI notification. When the supervisor is assured that the form is complete and accurate, the supervisor will sign the form. The Rendering Provider Form and NPI notification will be forwarded to DMH-HRB.
       
    6. Upon receipt of the NPI, Human Resources will forward to CIO the Rendering Provider Form and will place the NPI notification in the employee’s personnel file.

      Alternate procedure in the event the Rendering Provider Form is automated; accordingly, this alternate procedure is subject to change. Instructions for the use of the automated Rendering Provider Form will take precedence over these procedures. 

      The manager will follow the instructions for use of the automated Rendering Provider Form. The NPI notification will be forwarded to DMH-HRB. DMH-HRB will use the NPI notification to verify the NPI has been accurately entered in the IS. DMH-HRB will file the NPI notification in the employee personnel’s file.

       
    7. When an employee terminates services with DMH, managers/supervisors are required to report the termination to CIO by completing a Rendering Provider Form.
       
    8. When an employee transfers to a different clinic, managers/supervisors are required to report the transfer by completing a Rendering Provider Form terminating the employee from the clinic from which the employee is departing. Managers/supervisors at the new clinic are required to complete a new Rendering Provider Form so that services may be claimed for the new site.
       
  3. DMH Directly-Operated Clinics and Programs
     
    1. The Chief of Mental Health Programs Evaluation, Compliance Program Office (CPO), or designee, will apply for and obtain entity NPIs for each directly-operated clinic no later than October 1, 2006. The State requires an NPI for each provider number.
       
    2. The Chief of Mental Health Programs Evaluation will be responsible for maintaining NPI user IDs and Passwords, as well as a copy of the application and NPI notification.
       
    3. After October 1, 2006, as new directly-operated clinics and/or programs are added, applications for NPIs will be submitted by the Chief of Mental Health Programs Evaluation (or designee) upon receipt of a Provider File Adjustment Request (PFAR).
       
    4. It will be the responsibility of Program Managers to ensure that a copy of PFARs for directly-operated clinics/programs be submitted to the CPO within 15 calendar days of a change of clinic/program information. Using the PFAR, the Chief of Mental Health Programs Evaluation (or designee) will ensure the NPPES information is updated within 30 calendar days from the change.
       
  4. Fee For Service (FFS) Network Providers 
     
    1. FFS providers who are individuals will obtain a Type 1 NPI.
       
    2. FFS providers who are operating as an organizational provider will obtain a Type 2 NPI.
       
    3. FFS providers shall follow Instructions for Applying for an NPI.
       
    4. FFS providers are responsible for retaining a copy of their NPI notification.
       
    5. FFS providers are responsible for updating their and/or entity NPI data submitted to NPPES within 30 calendar days of any change(s) occurring. Updating NPI data is a HIPAA requirement effective January 23, 2005. (45 CFR Part 162)
       
  5. Legal Entity Contractors
     
    1. As of May 23, 2008, all claims will be submitted to the State with organizational and rendering provider NPIs. Each mental health contractor, regardless of program, will obtain a Type 2 NPI. The State requires one NPI for each provider number. (Locations identified as satellites each need their own NPI number.)
       
    2. In the event of a new rendering provider, the NPI shall be submitted to the Department using a Rendering Provider Form.

      NOTE: The NPPES does not recognize an effective date for the NPI. The date to use in completing the Rendering Provider Form is the date of the NPI notification.

       
    3. Legal Entity Contractors will retain a copy of their employee NPI (Type 1) and organizational (Type 2) NPI notifications for audit purposes.
       
    4. Legal Entity Contractors are responsible for terminating rendering providers that have been active on the system but are no longer claiming or have terminated employment with the legal entity through the use of a Rendering Provider Form.
       
    5. Legal Entity Contractors are responsible for updating entity NPI data submitted to NPPES within 30 calendar days of any change(s) occurring. Updating NPI data is a HIPAA requirement effective January 23, 2005. (45 CFR Part 162) 
       
  6. Legal Entity Contract Employees 
     
    1. All DMH contractor entities shall direct employees who are rendering providers (clinicians) or providers of direct billable services to apply for and obtain an individual NPI.
       
    2. See Attachment II for NPI application instructions.
       
    3. Legal Entity Contractors will retain a copy of the employee NPI notification for audit purposes.
       
    4. Legal Entities will submit rendering provider NPI information to CIO on a Rendering Provider Form. 

      NOTE: The NPPES does not recognize an effective date for the NPI. The date to use in completing the Rendering Provider Form is the date of the NPI notification. Copies of NPI notifications for contractor employees should be retained by contractors for audit purposes.
       
    5. Legal Entity rendering providers are responsible for updating their NPI data submitted to NPPES within 30 calendar days of any change(s) occurring. Updating NPI data is a HIPAA requirement effective January 23, 2005. (45 CFR Part 162)
       
    6. Legal Entities are responsible for submitting a rendering provider form terminating the rendering provider NPI on the IS when the rendering provider terminates employment with the legal entity.
       
  7. Chief Information Office (CIO)
     
    1. CIO will ensure that the IS programmatically validates that the supplied NPI numbers meet federal requirements for field length (10 numeric digits) and comply with the formula for the check digit algorithm.
       
    2. System verification required for implementation by the Medicare Intermediary and the State, utilizing NPIs must be completed before the March 1, 2008, for Medicare and before May 23, 2008, for Medi-Cal and other providers, to ensure compliant billing transactions can be performed as of the federal implementation dates.
       
    3. CIO will operate the IS claiming system in compliance with the HIPAA requirement to submit all electronic billing data in a compliant manner and will include NPI data effective March 1, 2008, for Medicare, and May 23, 2008, for Medi-Cal and other programs.