The Centers for Medicare & Medicaid Services (CMS) announced today that it is initiating a contingency plan that extends the compliance date for the National Provider Identifier (NPI) from May 23, 2007 to May 23, 2008. Physician practices, covered under the Health Insurance Portability and Accountability Act (HIPAA), are required to get NPIs for the organization and their providers, and submit those numbers on all HIPAA electronic standard transactions, including claims. Medicare is requiring use of the NPI on the revised paper 1500 claim form. This contingency plan announcement mirrors MGMA’s recommendation to CMS in testimony before a federal advisory panel in January. The CMS enforcement process is complaint driven and will allow covered entities to demonstrate good faith efforts and employ contingency plans. If a complaint is filed against a covered entity, CMS will evaluate the entity’s “good faith efforts” to comply with the standards and would not impose penalties on covered entities that have deployed contingencies to ensure that the smooth flow of payment continues. Each covered entity will determine the specifics of its contingency plan. Contingency plans may not extend beyond May 23, 2008, but entities may elect to end their contingency plans sooner. Medicare will announce its own contingency plan shortly.