March 29, 2006

Jeffry Blair
Harry Reynolds
National Committee on Vital and Health Statistics
Humphrey Building, Room 440-D
200 Independence Avenue, S.W.
Washington, DC, 20201

Chairmen,

The National Association for Home Care & Hospice (NAHC) advocates for the needs of the over 10,000 Medicare certified home health and hospice providers, as well as the thousands of non-certified providers of home care services. NAHC is writing to offer our comments about the concerns raised by providers of home care and hospice services related to the National Provider Identifier (NPI).

Home care providers deliver and bill electronically for a wide array of services in the home, as well as other community sites such as adult day care centers. Provider types range from one-site entities that deliver a single service, such as home health aide service, to complex entities that deliver a full range of services and specialty programs from multiple sites spread over large geographic areas. Services include, but are not limited to: physical, occupational, and speech therapy; nursing; home health aide; medical social work; medical supplies; durable medical equipment; infusion therapy; respiratory therapy; dietician; physician; telehealth; in-home and institution based hospice services; and adult day care. 

Home care and hospice providers share concerns similar to those expressed by the National Uniform Billing Committee (NUBC) in its recent letter to NCVHS on behalf of institutional providers. NAHC agrees that health plans, including government plans such as Medicare, Medicaid, and private insurances may not be able to adapt to the provider’s decision about their NPI(s). 

We believe that the goal of the NPI, that is a single provider number for use with all payers, will not be realized without further work. Billing requirements vary by payer based on how payers wish providers to identify themselves and their varying sites and services in order to ensure proper payment, whether that payer is Medicare, Medicaid, or private insurance. We hope that the following examples of some payer requirements currently in place will give NCVHS a perspective of the potential problems related to national provider number assignment:

• Medicare assigns separate provider numbers to subunits of home health agencies that are geographically separated despite the fact that these subunits share the same EIN with the parent agency.
• Medicare also assigns separate provider numbers to subunits of hospices that are geographically separated despite the fact that these subunits share the same EIN with the parent.
• For survey and certification purposes and payment, Medicare requires home health agencies to secure branch identifiers for locations that are geographically separated from the parent but are billed to Medicare under the parent provider number. The numbering logic for branch offices is built on the current Medicare parent’s provider number. Since home health agencies have been advised to obtain a single NPI for their parent and branch sites, it is unclear how branch offices will be identified. Furthermore, home health agencies prefer to have a separate identifier for their branch offices in order to be able to differentiate and benchmark their Outcome Assessment and Information Set (OASIS) data and outcomes for their branch sites.
• Medicare requires home health agencies that bill durable medical equipment under the Part B benefit to obtain and bill using a separate supplier number.
• Medicare requires home health agencies that bill for infusion therapy to obtain a separate number to bill for the drugs as pharmacy services.
• Some private insurance plans require home health agencies delivering therapy services to bill using a number assigned by the payer to each individual therapist rather than with an agency provider number. Payers then tie the therapists’ numbers to the provider through their internal system logic. In cases where more than one therapist sees a patient (e.g. one or more occupational, physical and speech therapy) separate claims must be submitted for each therapist despite the fact that the home health agency is the provider.   

Other concerns have also been raised, including the rumor that the Centers for Medicare and Medicaid Services (CMS) is considering continuation of Online Survey, Certification and Reporting system (OSCAR) numbers for Medicare providers. Finally, providers are worried about the potential negative impact of payment for multiple sites and business lines to a single provider number on their ability to properly allocate payments. 

Home health and hospice providers have raised questions as to the wisdom of the NPI initiative as it is today. Their opinion of what is taking place is the “switching a set of provider numbers for a new set of provider numbers.” They question what will be accomplished if the examples cited above are not addressed and they are required to continue to have multiple numbers.

We thank you for the opportunity to express some of the concerns of home care and hospice providers related to the NPI process. If you have additional questions, please contact me at (202) 547-7424 or by e-mail at mts@nahc.org.

Sincerely,

Mary St.Pierre
Vice President for Regulatory Affairs