LOS ANGELES COUNTY
DEPARTMENT OF MENTAL HEALTH
  Policy 106.14 National Provider Identifier Requirements
 
Policy Category:  Administrative
Distribution Level:  Directly Operated Programs and Contracted Agencies
Responsible Party:  Compliance, Privacy, and Audit Services
 
Approved by Marvin J. Southard, DSW, Director, on September 1, 2008
 
I.  PURPOSE
 
To ensure all directly operated programs, non-governmental agencies (NGAs), organizational providers, and individual rendering providers, working for or contracted with the Los Angeles County Department of Mental Health (DMH/Department) have a National Provider Identifier (NPI) before March 1, 2008, for Medicare and before May 23, 2008 for Medi-Cal and other programs so that eligibility for reimbursement is continued.

To establish guidelines for the submission of verifiable NPI information from DMH employees, other DMH workforce members, and contract entities, needed to support continued billing under Health Insurance Portability and Accountability Act (HIPAA) requirements.

To establish procedures for obtaining NPIs for new DMH staff (those hired after May 23, 2008).

To establish procedures for obtaining NPIs for new directly operated clinics/programs.

To establish procedures for obtaining NPIs for new contracted operated clinics and programs.

To establish procedures for obtaining NPIs for contract employees hired after May 23, 2008.

To provide general information about NPIs.  

To ensure there is proper internal control over the NPI data submitted to the Integrated System (IS) for active and inactive (terminated) employees.
 
II.  DEFINITIONS
 
DMH Employees: For the purpose of this policy, any full-time or part-time, temporary or permanent employee rendering provider (clinician) who provides clinical or direct billable services to clients. Each requires an NPI.

Other DMH Workforce Members: Residents, interns, students, volunteers, and locum tenens.

Contractor: A person or entity that is party to a written agreement with the County of Los Angeles to provide goods or services to DMH including, but not limited to, purchase orders, memoranda of understanding and Board approved contracts.

National Provider Identifier (NPI): A number that serves as a unique identifier at the national level for entities and individuals and is a HIPAA requirement (45 CFR Part 162) effective January 23, 2005. Eventually, the NPI will replace all other assigned provider numbers.

National Plan and Provider Enumeration System (NPPES): a national database accessible through the internet used for purposes of applying for an NPI. It is the NPPES database by which health care provider organizations and individuals become uniquely identified, formerly known as the National Provider System. The NPPES assigns an identifier only and is NOT an enrollment process with any Medicare contractor, Medi-Cal contractor, or third party payer. 

NPI Notification: The e-mail that contains the NPI number for either an individual or entity. The date of this notification is considered by DMH to be the effective date of the NPI.
 
III.  POLICY
 
DMH will comply with HIPAA requirements, as established in the 45 CFR Part 162, to establish NPIs for the following:
  • Each entity (DMH directly operated program and NGA must have an NPI as a unique identifier in the National Plan and Provider Enumerator System (NPPES). This is referred to as a Type 2 NPI on the NPPES. The State requires one NPI for each provider number without satellites. Locations identified as satellites must have their own NPI numbers.
     
  • Each rendering provider delivering direct billable services must have an NPI as a unique identifier in the NPPES. This is referred to as a Type 1 NPI on the NPPES.
All claims submitted to Federally funded health care and other programs must include the entities’ and the rendering providers’ NPIs effective March 1, 2008, for Medicare and May 23, 2008 for Medi-Cal and other programs.

System verification required for implementation by the Medicare Intermediary and the State, utilizing NPIs must be completed before 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.

DMH employees and DMH contractors must provide written proof of their respective individual (Type 1) and organizational (Type 2) NPIs no later than May 13, 2008. Specifically, the DMH employees will submit a copy of their NPI notification. Contractors will only submit a copy of the NPI notification for organizational NPIs (Type 2). It will be the responsibility of the contractors to maintain copies of their employees’ individual NPI notifications for audit purposes.

NPIs are considered to be a condition of employment. A rendering provider or DMH employee who provides billable services must be eligible to bill Federal Programs (DMH Policy 106.03). Consequences for non-compliance with applying for, obtaining and providing written proof of an NPI may include, but are not limited to, the following: 
  • DMH employees may be subject to progressive disciplinary actions that may lead to termination. (DMH Policy 605.01)
     
  • Fee-For-Service (FFS) Network Providers may have their contracts terminated for cause as they will not be eligible to bill for services without an NPI.
     
  • Legal Entity Providers who do not have or are missing individual NPIs will not be able to submit claims to federally funded health care and other programs. Consequently, their respective contract(s) may be subject to termination.
IV.  PROCEDURES
 
V.  AUTHORITY
 
VI.  ATTACHMENTS