William:

I agree that the lack of standard Provider IDs is a problem.  However, if
the suggestion is that the industry ought to embrace the DUNS number (or any
other number) as an unofficial standard, then I would object to that
concept.  The problem with that idea is that the release of the final NPI
regulation is hanging over us.  

Enumerating providers is not an easy thing to do.  The communication of the
new numbers and the process for doing this is time consuming and costly in
terms of time, money, and resources.  There is significant work involved in
creating new provider tables/databases, loading this information, and making
sure that all systems process this information correctly.  Finally, there
will undoubtedly be claim processing problems as an entity migrates from one
number to the next.

If the industry (or parts) were to move to DUNS and HHS releases an NPI
regulation which uses anything other than DUNS (which it is expected they
will do), the industry will have to discard all the work to move to DUNS and
re-duplicate the effort.  There would be no way for the industry to
recapture the lost time, effort, and money that it spent moving from today's
proprietary IDs to the NPI.

The companies I work for have been poised to move to new provider IDs for a
number of years now and have been unwilling to pull the trigger for fear
that immediately after we do so the HHS reg will come out and the whole
thing will be wasted.  I would not be surprised if the same is true with
other carriers.  The best thing for all concerned is for HHS to release the
NPI reg and for providers to act quickly in getting their new ID numbers.
(Keep in mind that the move to a standard could break down if Providers
don't hold up their end by getting these numbers.)

The same is true with standard group IDs and payer IDs, for what it is
worth.

Ken Fody
Independence Blue Cross

-----Original Message-----
From: William J. Kammerer
To: WEDi/SNIP ID & Routing
Sent: 3/28/02 3:42 PM
Subject: Re: Payers sure do like proprietary provider IDs!  Do providers
feel the same way?

The National Provider ID (NPI) registrar will certainly not be assigning
IDs to providers based on "contract" number, so it's clear that payers
will already have to be working on separating the notion of contract
from that of provider ID in their HIPAA remediation efforts.  So whether
payers used the NPI, D-U-N-S, DUNS+4, HIN, or Federal Tax ID to identify
providers, assignment of these IDs will necessarily be based on licensed
entity, individual, location or role - but never on the contract with
the particular payer.

Nonetheless, even though we're sometimes forced to discuss the general
notion of IDs as used in the application transaction sets, our primary
problem to solve is getting some consistent way of identifying providers
as EDI participants - and getting everyone (including payers) to use
that same ID for looking up providers' EDI addresses (inter alia) in the
Healthcare registry.  It will be a great step forward if our small group
gets all players singing from the same hymnal as far as ISA
identification goes;  it would be icing on the cake, indeed, if interim
application solutions to the lack of an NPI came out of our group, too!

It sounds like we're coming to some sort of agreement that not only
providers, but payers, too, find it cumbersome to deal with proprietary
payer-assigned IDs as EDI Identifiers on the ISA.  Are we getting closer
to being able to make some definitive statement whereby we recommend
that all providers' (or their agents') EDI portals be identified by
DUNS, DUNS+4, HIN or Tax ID (the only current relevant choices in the
Interchange ID Qualifier)?

William J. Kammerer
Novannet, LLC.
+1 (614) 487-0320


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