NPI Contingency Plan

Expires May 22, 2008

Community Health Plan will continue to accept legacy provider identifiers during the 12-month contingency period established by CMS. Community Health Plan will monitor providers who continue to submit transactions with legacy provider identifiers during the contingency period and will work with them to bring them into compliance with NPI regulations.

Community Health Plan is able to accept HIPAA transactions with and without an NPI (“dual use”) on May 23, 2007. This action is taken in order to maintain operations and cash flows and is meant to support the provider community and the delivery of health care services.
Community Health Plan will continue to communicate with providers that a contingency plan does not replace their obligation to obtain an NPI and to report their NPI to Community Health Plan as soon as possible. The Provider newsletter, the Community Health Plan website FAQ and Provider Relations staff are the avenues for communicating with the provider community.
Community Health Plan will continue to enter collected NPI into applicable software systems.
Community Health Plan will expect of its Business Associates a same or similar contingency plan that maintains operations and cash flows (treatment, payment and operations) and that all NPI ready systems, as of the date of this memo, will remain ready, current and functional in preparation of the May 23, 2007 compliance date. Community Health Plan will only require a covered entity to submit their NPI contingency plan upon request.

This contingency plan is subject to revision dependent on future CMS guidance and actions.