The CMS updates NPI files on a weekly basis, providing simply the “delta” of changes from the week before. If it is not, then having the NPI will not help you determine which employees are on the exclusion lists. The concern, however, is making sure that the database for the exclusion lists is current. So you really want to make sure you have every provider’s NPI on file. In fact, using a unique numerical identifier is far less subject to error than entering people’s names and so on, where a misspelled name in the record, for example, could lead to a false negative for someone who really has been excluded – or, for that matter, a false potential match, for someone who has not. The capabilities of being more accurate has most definitely increased since the OIG started upgrading their federal and state databases to include NPIs. Now, the logistics of cross-referencing healthcare providers with the OIG’s exclusion lists by means of the healthcare providers NPIs are not quite as simple as one might wish them to be.
And most importantly for the matter at hand, a few years ago the OIG began updating their exclusion lists with NPI numbers, making the screening process far more accurate.
Moreover, any electronic record system may use NPIs in patient records, where a treatment facility or physician of record is identified, or any time legal identification is required, for that matter. So when are NPIs used beyond when they must be for HIPAA regulated transactions? Well, for example, healthcare providers may choose to identify themselves or other healthcare providers via their NPIs in correspondence, in internal files, on prescriptions, and when healthcare providers coordinate health plans with other healthcare providers. Medical billing personnel, for example, as well as others who provide support services (such as a custodial team or orderlies) fall into this exempt category. Note that some of those who work in the healthcare industry are nonetheless not considered healthcare providers, and they are not required to register for an NPI (although they still may be listed on exclusion lists and must be checked for). Organizational healthcare providers for whom NPIs are mandated include hospitals, pharmacies, laboratories, home health care agencies, residential treatment centers, nursing homes, medical equipment companies, and more. As an example, a doctor NPI lookup would mean first conducting the NPI search by name, and thereby obtain the NPI number, or alternatively, search the NPI registry for all doctors, and hone in on the ones under scrutiny, find their NPI, and then search via the NPI number.
These individual providers include physicians, dentists, nurse practitioners, midwives, pharmacists, physician assistants, physical therapists, occupational therapists, athletic trainers, and more. Note that NPIs are assigned to the providers they identify on a permanent basis, even if the providers change jobs, locale, or name. Individual healthcare providers whose activities are under the jurisdiction of HIPAA must have an NPI – if for no other purpose than for all of their electronic transactions that pertain to HIPAA regulations, though once NPIs came into use, NPI registry searches take place more commonly than for those under the jurisdiction of HIPAA alone (see below).
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