UnitedHealthcare and Its Affiliates Contingency Plan 2007
UnitedHealthcare and Its Affiliates will initially accept transactions sent to us without NPI or with incorrect NPI to ensure uninterrupted transaction processing to our physicians, health care professionals and organizations and avoid service issues for our customers.  Furthermore, we will not reject transactions that contain other legacy identifiers in addition to NPI.  We are working towards a timeframe in which we will not accept HIPAA transactions that require an NPI, but are received without an NPI or with an invalid NPI. The goal is to be in full-compliance on or before May 23, 2008. Any changes to our current policy for accepting transactions without NPI will be preceded with communications to physicians, health care professionals, organizations and trading partners regarding when we expect to begin to not accept HIPAA transactions that do not contain a valid NPI in the fields specified by the Implementation Guide.
The following pages include UnitedHealthcare and Its Affiliates’ state of readiness for NPI Compliance for each standard HIPAA transaction. 

Details on areas we are at risk for full compliance are also provided, including:

• Readiness for NPI as of May 23, 2007
• Reliance on Other Covered Entities for Compliance
• Our long term and transition plan for becoming compliant

External Reliance on Other Covered Entities for NPI Contingency
UnitedHealthcare, in conjunction with CMS, recognizes that transactions often require the participation of two covered entities, each of whom is required to comply with HIPAA, and that noncompliance by one covered entity may put the second covered entity in a difficult position.  For example:

• Trading Partners, including clearinghouses and providers who directly submit their HIPAA transactions - We currently are not rejecting HIPAA transactions that are sent without NPI.  As a result, there is a lack of clarity as to which party is non-compliant.  By May 23, 2008 we will not accept any HIPAA transactions that require NPI but are sent to us without an NPI or with an invalid NPI.  This will result in greater clarity and accountability on the part of trading partners to be HIPAA compliant with respect to NPI.
• Medicaid State Agencies - Contingency Plans have been announced by the Medicaid Agency in the following states:
  ─ Arizona – Arizona Health Care Cost Containment System (AHCCCS) – 1/1/08 Rendering Providers and 3/1/08
  All Other Provider Types
  ─ California – California Department of Health Services (CDHS) Medi-Cal
  ─ Florida – Agency for Healthcare Administration (AHCA) – 10/1/07
  ─ Maryland – Department of Health and Mental Hygiene (DHMH)
  ─ Michigan – Michigan Department of Community Health (MDCH)
  ─ Nebraska – Nebraska Health and Human Services System (HHS)
  ─ New Jersey – Division of Medical Assistance and Health Services (DMAHS)
  ─ New York – New York State Department of Health (NYSDOH)
  ─ Pennsylvania – Department of Public Welfare (DPW)
  ─ Rhode Island – Department of Human Services
  ─ Tennessee – TennCare
  ─ Texas – Texas Medicaid and Healthcare Partnership (TMHP) – 9/1/07
  ─ Wisconsin – Department of Health and Family Services (DHFS)
• Medicare Fee-For-Service (FFS) - The Medicare FFS Contingency Plan states that for some period after May 23, 2007, Medicare FFS allow continued use of legacy numbers; it will also accept transactions with only NPIs, and transactions with both NPI and legacy numbers.  After May 23, 2008 the legacy number will not be permitted on any inbound or outbound transactions.   
• Pharmacy Benefit Managers contracted with UnitedHealthcare and Its Affiliates must have the ability to accept a Pharmacy’s NPI on a National Council for Prescription Drug Program (NCPDP) transaction by May 23, 2008.  The NCPDP format permits the reporting of only one identifier, and will accept either NPI or legacy number on the NCPDP format until May 23, 2008.
• CMS’ dissemination of NPI data from NPPES also plays a role in the successful implementation of NPI. The NPI Data Dissemination Notice was released by CMS on May 23, 2007; however, the data is not anticipated to be available until August 2007. Our internal provider file is populated with approximately 25% percent of the NPIs required for our network. There is a dependency on matching a provider’s NPI on file to data received in a HIPAA transaction.  NPI data is also critical in building a complete and accurate crosswalk of NPI to legacy identifiers.  An incomplete crosswalk may inhibit or delay processing of transactions.

Transition Plan

• Our goal is to not accept HIPAA transactions that require an NPI, but are received without NPI or
  with invalid NPI by May 23, 2008.
• Determine timing on whether UnitedHealthGroup will not allow HCFA-1500 and UB-92 paper
  submissions, but require full compliance with use of the HICF-1500 and UB-04 without exception.
• Be in compliance with the NPI requirements on paper claims pertaining to Minnesota State Statute Sections 62J.50 – 62L.61 § 62J.54, and other state specific NPI regulations.
• Continue provider outreach activities in efforts to obtain their NPI (via Fax Form, Provider Services, Contracting, Credentialing, and external Web site www.unitedhealthcareonline.com).
• Continue to wait on availability of CMS NPPES download file to complete internal crosswalks. 
• Continue monitoring state specific requirements for Medicaid and collaborating with those state agencies to determine the timeframe we will implement system logic to not accept HIPAA transactions that require NPI but are received without NPI or with invalid NPI.
• Continue communications with our clearinghouses and other trading partners on our state of readiness including replies to surveys.
• Analyze platforms that are sun setting to determine the impact of NPI and prepare for May 23, 2008.
• Identify methods to track HIPAA transactions submitted without NPI.

Measurable Goals, Milestones and Timeline