Actually, in the WEDi/SNIP ID & Routing group, we're merely concerned with the manner in which entities are identified in the ISA interchange header (and perhaps the GS) segment for routing. As Rachel said yesterday, "the focus [of our group is] on the 'functional use' of the identifier in the ISA as the key to discovering the detailed EDI addressing information." Sometimes we do talk about the problems with the lack of standard identifiers (especially for providers) in the application transaction sets, but it's not in our charter to solve that big, hairy problem!
But as it stands, there are only a few ways entities can be identified in the ISA based on the constraints HIPAA imposes on the ISA Interchange ID Qualifier. For providers, it leaves us with only the D-U-N-S (and D-U-N-S with suffix), the Federal Tax ID (or FEIN), or the HIN as acceptable domains for identifiers - if we rule out the 'ZZ' (Mutually Defined) qualifier (the ZZ qualifier is usually used for payer-assigned provider IDs, which are the bane of standardized identification). I assume that once the NPI is in place, there will be no problem getting it added as one of the acceptable ID types in the ISA. But until then, we're still left with problem of how a payer determines the type (D-U-N-S, FEIN or HIN) and value of the ISA receiver ID for a provider. Some of the more recent discussion has suggested taking an identifier the provider is known by to the payer (e.g., the FEIN), and using that ID to search the Registry for the provider's CPP, which in turn contains the provider's preferred ISA ID (and that preferred ID may be the FEIN itself, or another Tax ID, or one of the provider's D-U-N-S numbers). Keep in mind that if the Registry is powerful enough to be searched by any (non-proprietary) ID, then the sender could just blindly stick the FEIN in the ISA receiver ID, knowing full well that a VAN or CH intermediary could search the Registry for the CPP which contains the EDI addresses and ports. The whole concept of a "preferred" ID may give way to a more powerful notion whereby a receiver can be identified in the ISA by any of its known IDs (whose domains or type are allowed by the HIPAA IG). William J. Kammerer Novannet, LLC. +1 (614) 487-0320 ----- Original Message ----- From: "Fody, Kenneth W." <[EMAIL PROTECTED]> To: "'William J. Kammerer '" <[EMAIL PROTECTED]>; "'WEDi/SNIP ID & Routing '" <[EMAIL PROTECTED]> Sent: Friday, 29 March, 2002 02:01 PM Subject: RE: Payers sure do like proprietary provider IDs! Do providers feel the same way? 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
