Testimony of the American Dental Association
National Committee on Vital and Health Statistics
Subcommittee on Standards and Security
January 24, 2007

Mr. Blair, Mr. Reynolds and members of the Subcommittee thank you for inviting the American Dental Association (ADA) to testify on the National Provider Identifier (NPI) and the readiness of Dentists to meet the May 23^rd, 2007 deadline.  My name is Frank Kyle and I am a Manager for Legislative and Regulatory Affairs for the ADA here in Washington, DC but today I represent my colleagues in our Chicago headquarters who are the experts in health information technology and heath informatics for the association.  The ADA is the world’s oldest and largest dental professional association and represents over 153,000 dentists or almost seventy-two percent of the dentists in clinical practice in the United States.  The ADA has been involved in promoting the NPI to its members even prior to the publishing of the Final Rule and is pleased to provide our insight into the questions and concerns our members have expressed concerning the NPI.  We will also share with you our estimate of the readiness of dentists and dentistry to implement the NPI this coming May.

Taking the subcommittee’s questions in order:

1.  What if any issues have our members (or dentists in general) had relative to applying for and using the NPI?

• Solo dentist corporations and multi-doctor organizations are uncertain whether to apply for individual, organization, or both NPI entity types.
• The paper application has confused many applicants despite the instructions provided with the application form.
• The configuration of NPPES site is confusing to some applicants.
• Dentists are unfamiliar with Provider Taxonomy codes and where to obtain them.
• NPI confirmation notices have been ignored or lost by applicants.
• There is uncertainty about where or how to use NPIs on paper claim forms.
• Many billing systems are outdated and need expensive hardware and software updates.
• There has been some frustration with NPI Enumerator customer service.

2.  Are there any concerns specific to our members’ (or dentistry's) interests?

• Implementation Strategy Concerns
  1. Vendor readiness – some practice management system vendors have not yet updated their software to include the NPI.  In addition, some vendors are not willing to update current versions and are requiring that dentists purchase new versions of hardware and software to accommodate the NPI.  One dentist contacted the ADA recently and said that their current vendor was not going to update the current version in use today and instead the dental office would be forced to purchase a new system for $30,000-$40,000 dollars or return to submitting paper claims.
  2. Trading Partner Flexibility - most of the electronic transactions that are sent from a dental office go through some type of clearinghouse for translation into the appropriate format.  The clearinghouse function could be accomplished by routing a claim to the practice management system vendor utilized by the dental office and then the transaction may go on to a clearinghouse and eventually a payer.  Or, the transaction may go from a dental office directly to a clearinghouse. These vendors are considered trading partners.  The trading partners should be capable of transmitting all the appropriate data elements required by HIPAA – including the NPI.   
  3. Testing-the ADA does not have the ability to track the status of the testing phase for transaction compliance of dental claims but based on some of the comments we have received the ADA believes payers/clearinghouses are behind schedule.
  4. Dual Use (Legacy ID and NPI) – ADA agrees with WEDI’s recommendation for HHS to establish a contingency plan to allow use of legacy identifiers for 12 months after the industry has access to the NPPES data
  5. Transition Plan
• Paper form implications-will the payers require NPIs on paper claims?
• Payment Continuity Concerns
  1. Revenue Cycle Management
  2. Payment Monitoring
  3. Error Resolution Plan
• Data Requirements
  1. Payer Crosswalk Solutions – NPI, Legacy ID, Other Data
  2. Taxonomy Code – will taxonomy codes be required on claims
  3. Validation Criteria with the Payers
  4. Availability in Practice Management Systems

3.  What, if any, education and outreach has the ADA conducted relative to NPI?

• 8 articles on the NPI in the ADA news:
  1. No need to buy NPI Kits - posted 08/08/2006
  2. How to apply for your NPI - posted 07/11/2006
  3. The national provider identifier - posted 07/11/2006
  4. Its time to apply for a National Provider Identifier - posted 05/09/2006
  5. Doctor, who are you? - posted 06/06/2005
  6. Association launches NPI information campaign - posted 05/23/2005
  7. National provider identifier application process begins May 23 - posted 05/17/2005
  8. Feds set sights on national identifier system for health care providers - posted 02/16/2004
• Numerous materials on the ADA website at www.ada.org/goto/npi
• Brochures and posters were available at the ADA Annual Session in October 2006.
• The ADA worked with the National Dental Electronic Data Interchange Council (NDEDIC) for the development of NPI outreach materials aimed at dentists in July and August of 2006 and will be participating with NDEDIC to present a Webinar in February 2007.
• Presentations by ADA representatives were given at the HIPAA Summit (April 2006); NDEDIC (May 2006); and the WEDI May and November Annual Conferences.
• An ADA representative is a co-chair to the WEDI NPI Outreach Initiative (NPIOI).
• In addition, in 2006 the ADA responded to approximately 1200 calls related to the NPI and answered approximately 300 e-mails

4.  What is our evaluation of dentist readiness to successfully respond to NPI implementation beginning May 23, 2007?

Based on information obtained from CMS in early December of last year, 86,400 dentists have applied for their NPI.  Based on the information from the ADA’s Research Center, we estimate that number represents 58 percent of all dentists in clinical practice, either full time or part time.  However, that number may be an underestimation if we attempt to analyze the number of dentists that file claims electronically.  Again According to the ADA Survey Center, in 1994 the number of dentists submitting electronic claims was 9.4 percent and by 2000 the number was 41.8 percent for an average rate of increase of 4.53% per year over the period.  Using that projection from the 2000 number, the ADA estimates 69 percent of dentists will submit claims electronically in 2006.  If that number is correct, then approximately 85 percent of dentist likely to need an NPI by May 23^rd have already obtained one.

While substantial numbers of dentists have enrolled for and received their NPI, the ADA believes that only a fraction of providers have successfully transmitted those numbers to the payers resulting in little or no testing of implementation. If there are problems with the process, claims payments would be adversely affected, putting all providers at a significant financial risk.

The ADA is also concerned that the Department of Health and Human Services has not yet released their dissemination notice outlining who has access to the National Plan and Provider Enumeration System (NPPES) data and the process for obtaining that data. The ADA believes this could adversely affect how the payers crosswalk the NPIs to their legacy IDs. The ADA believes that even if the notice were released today, there is not enough time to accomplish this task and meet the May 23 deadline. Therefore the ADA agrees with the WEDI recommendation that HHS should develop a contingency plan that will allow the use of legacy identifiers for at least 12 months after the industry has access to NPPES data.

Once again, thank you for the opportunity to present information relative to dentistry’s readiness for the implementation of the National Practitioner Identifier.  I will be happy to try to answer your questions or refer them to our experts in Chicago.

Frank A. Kyle, Jr., D.D.S., M.S.
American Dental Association
1111 14^th Street, NW, Suite 1100
Washington, DC 20005
202-789-5175
202-789-2258 (Fax)
kylef@ada.org