While BlueCross BlueShield of South Carolina will be compliant by the deadline, we understand all providers and trading partners may not be ready at that time. As a result, BlueCross will enter into a contingency period that will allow trading partners to continue to submit transactions that contain Legacy Identifiers after the May 23, 2007 compliance date. This will give providers more time to test and prepare for an NPI-only environment.

During this contingency period, providers will be allowed to submit electronic and paper claims with either:

• Legacy Identifiers only
• Both Legacy Identifiers and NPIs
• NPIs as the only provider identifier
  

BlueCross recommends that providers test their enumeration strategy by submitting transactions with both Legacy Identifiers and NPIs for a minimum of 30-60 days before submitting transactions using NPI as the only provider identifier.

BlueCross will continue to work with providers to help them transition from Legacy Identifiers to NPIs. During the contingency period, providers must be able to demonstrate good faith efforts to comply with the federal law. Individual provider readiness will depend on their various systems and vendor production schedules. We expect providers and trading partners will be able to reach full compliance well before the mandatory "end of contingency" date of May 23, 2008.

In July 2007, BlueCross will evaluate the readiness of the provider community. If we have a sufficient number of claims submitted with NPIs, we will begin to reject claims on August 1, 2007 that do not have NPIs. If a sufficient number of claims do not contain NPIs, we may issue a revised date when we will begin to reject claims.

Primary and Secondary Identifiers
BlueCross will implement edits that remain consistent with CMS guidance provided its Fiscal Intermediaries in Transmittal 1227 for Change Request 5595 dated April 24, 2007:

"Once a decision is made to begin requiring NPIs on claims, primary providers i.e., billing, pay-to and rendering providers must be identified by their NPIs or the claims will be rejected once the decision is made as indicated above."

"All other providers are considered secondary providers and include referring, ordering, supervising, facility, care plan oversight, purchase service, attending, operating and "other" providers. Legacy numbers are acceptable for secondary providers until May 23, 2008. If the NPI is present for secondary providers, the NPI must only be edited to determine that it has 10 digits; begins with 1, 2, 3, or 4 and that the 10th position of the number is a correct check digit."

835 Remittance Advice

Until BlueCross announces its end of the NPI contingency period or May 23, 2008 (whichever comes first):

• If a provider submits a claim with a Legacy Identifier and we can find a corresponding NPI in our provider file, we will send both the NPI and Legacy Identifier on the associated 835 remittance advice. If we can not find an NPI in our provider file, we will only provide the Legacy Identifier.
• If a provider submits a claim with both the NPI and Legacy Identifier, we will send both the NPI and Legacy Identifier on the associated 835 remittance advice.
• If a provider submits a claim with only an NPI, we will continue to send both the NPI and Legacy Identifier on the associated 835 remittance advice.
  

If you have questions, please contact BlueCross EDI Services via e-mail at NPI.ADMIN@bcbssc.com.