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CMS Learn Resource 200711-22 Social Security Numbers (SSNs) Should Not Be Reported in FOIA-disclosable NPPES Fields As CMS has mentioned in previous outreach messages and on the CMS NPI Web site, some health care providers have reported their Social Security Numbers (SSNs), or the SSNs of other health care providers, in their NPPES records in fields that the Freedom of Information Act (FOIA) requires that CMS make publicly available. For example, there are instances where SSNs are reported in the “Other Provider Identification Numbers,” “License Number,” and “Employer Identification Number (EIN)” fields in providers’ NPPES records. The information that providers report in these (and certain other) fields is fully disclosable by CMS to the public and, therefore, SSNs should never be reported in any of these fields. Because SSNs are nine-digit numbers, CMS has been suppressing all nine-digit numbers found in any FOIA-disclosable field except for ZIP code and telephone/fax number fields. This means that these nine-digit numbers—whether or not they are SSNs--are not displayed in the NPI Registry and cannot be found in the monthly NPPES downloadable file. If these nine-digit numbers are legitimate EINs, “Other Provider Identification Numbers,” or “License Numbers,” health plans and others who are using the NPI Registry and the downloadable file are not able to see them, which means that they cannot see all of the NPPES data they may need in order to accurately match providers in NPPES to the providers in their own files, thus making it more difficult to link NPIs to legacy identifiers. In some cases, this may adversely affect payments to providers by health plans. It is imperative that providers immediately look at their NPPES records to ensure that they did not inadvertently report their, or someone else’s, SSN in a FOIA-disclosable field; if they did, they need to delete that SSN immediately and, if appropriate, replace it with the correct information (e.g., an EIN). Providers must look in their NPPES records (https://nppes.cms.hhs.gov/  )
in order to view all of the information they reported. If they need
assistance in deleting inappropriately reported SSNs, they may contact
the NPI Enumerator at 1-800-465-3203. If they need assistance in knowing
which NPPES fields are disclosable under FOIA, they should review
the document entitled, “National Plan and Provider Enumeration
System (NPPES) Data Elements Data Dissemination – Information
for Providers,” dated June 20, 2007, and found at http://www.cms.hhs.gov/NationalProvIdentStand/Downloads/NPPES_FOIA_Data%20Elements_062007.pdf
on the CMS NPI Web page.
Providers cannot rely on the information disclosed in the NPI Registry or in the downloadable file in trying to determine if they inappropriately reported SSNs in FOIA-disclosable fields because CMS suppresses these numbers, as explained above; these numbers will not be seen in the NPI Registry or the downloadable file. In order to protect your personal information from public disclosure, please correct this information immediately if this situation pertains to you. When to Contact the NPI Enumerator for Assistance
Health care providers needing assistance on any of the above topics may contact the NPI Enumerator at 1-800-465-3203, TTY 1-800-692-2326, or email the request to the NPI Enumerator at CustomerService@NPIenumerator.com. The NPI application form, itself, is also a good source of information. Please refer to the NPI application instructions for clarification on information to be submitted in order to obtain an NPI or update an NPPES record. Refer to the 'Application Help' tab located on the NPPES Web site for additional assistance while online. Important Information for Medicare Providers Medicare’s Key Dates
Be Sure to List Medicare Legacy Identifiers in the Appropriate
Fields in NPPES!
If claims are rejecting, providers should review their
NPPES records (not their NPI Registry records), to confirm that
Medicare legacy identifiers are reported in the appropriate fields
of the “Other Provider Identification Numbers” section.
Test Your Claims Now! As stated in an earlier November NPI message, since October 15, 2007, Medicare physicians, non-physician practitioners and other providers and suppliers who bill carriers and Medicare Administrative Contractors (MACs) using the ASC X12N 837P receive informational warnings that indicate if there was no NPI shown in the primary provider fields in those claim(s). Medicare is including these informational warnings on your pre-pass reject reports provided to you directly or to your bulletin board. The informational warnings consist of one or more of the following messages: M389 2010AA NM108 Billing Provider Identification Code Qualifier Invalid value. The edit sets when the 2010AA loop and NM1 are submitted but NM108 does not contain XX. If the claim contains a 2300 REF01 = P4 and REF02 = 31 (VA claim), the edit does not set. M390 2010AB NM108 Pay To Provider Identification Code Qualifier Invalid value. The edit sets when the 2010AB loop and NM1 are submitted but NM108 does not contain XX. If the claim contains a 2300 REF01 = P4 and REF02 = 31 (VA claim), the edit does not set. M391 2310B NM108 Claim Level Rendering Provider Identification
Code Qualifier Invalid value. M392 2420A NM108 Detail Level Rendering Provider Identification
Code Qualifier Invalid value. Medicare informational warnings, called “Provider Identification Code Qualifier Invalid Value” messages, will be labeled M389, M390, M391, and/or M392, but, again, these are only reminders. If you receive one of these messages and you are certain that your claim was submitted with an NPI, you may wish to contact your clearinghouse or billing agent to ascertain the reason behind the message. It is possible that the clearinghouse or billing agent removed the NPI prior to submitting the claim to Medicare. You may also want to call your carrier/MAC to ask about the message and how you can correct future claims. Many Medicare physicians, non-physician practitioners, and other providers and suppliers are not using NPIs in their Medicare claims, even in the primary provider fields (Billing/pay-to and Rendering). While, until March 1, 2008, you may continue to submit legacy identifiers in these fields, we strongly encourage you to begin using your NPI as well. You may use the NPI/PIN pair or the NPI-only to identify the Billing/pay-to and Rendering Providers. By doing so, you should have sufficient time to correct any problems that came about prior to the requirement to use only the NPI in claims. Need More Information? Posted: 11/27/2007 |
