Some existing provider identifier systems assign multiple identifiers to a single health care provider in order to distinguish the multiple identities the health care provider has in the system. For example, in these systems, the health care provider may have a different identifier to represent each “pay- to” identity, contract or provider agreement, practice location, and specialty or provider type. Since the NPI is a unique identifier for each health care provider, it would not distinguish these multiple identities. Systems that need to distinguish these identities would need to use data other than the NPI to do so. The change to use other data would add complexity to the conversion to the NPI or to any other standard provider identifier, but it is necessary in order to achieve the goal of unique identification of the health care provider.
The complexity of the conversion would also be significantly affected by the degree to which health plans’ processing systems currently rely on intelligent identifiers. For example, a health plan may route claims to different processing routines based on the type of health care provider by keying on a provider type code included in the identifier. Converting from one unintelligent identifier to another is less complex than modifying software logic to obtain needed information from other data elements. However, the use of an unintelligent identifier is required in order to meet the guiding principle of assuring flexibility.
Specific technology limitations of existing systems could affect the complexity of conversion. For example, some existing provider data systems use a telephone keypad to enter data. Data entry of alpha characters is inconvenient in these systems. In order to mitigate this inconvenience, we would implement the NPI by initially assigning numeric NPIs. After all numeric possibilities have been exhausted, we would introduce alpha characters in one position at a time. This implementation strategy would allow additional time for systems with technology limitations to overcome conversion difficulties.
In general, the shorter the identifier, the easier it is to implement. It is more likely that a shorter identifier, such as the NPI, would fit into existing data formats.
The selection of the NPI does not impose a greater burden on the industry than the nonselected candidates.