Two important items that should be on every pharmacy's agenda this year are NPI and CMI. NPI stands for national provider identifier. CMI stands for consumer medication information. Here's why I say this.

First the NPI. The HIPAA regs call for the use of a new provider identifier come May 23 of this year. There are two levels of NPI. One is for the individual, and the other for an entity. When applying for an identifier for your pharmacy, you will need the entity NPI, not the individual NPI. The NPI will replace the NABP/NCPDP number you have been using on claims. The individual NPI is your personal identifier. While this is optional, it is a good idea to apply for one. This NPI would be used to identify you as the rendering provider in medication therapy management programs.

By now you should have applied for your pharmacy's NPI. If not, I would jump on it. This is not the end of the story, however. Once you have your pharmacy's NPI, you should register this number with all the third-party networks that you have contracts with. One way to simplify this process is to register your number with NCPDP. Go to http://www.ncpdp.org/frame_news_npi-info.htm for how to do this. But don't send your individual NPI. The last I heard, independents are far behind chains in getting their numbers on file. Keep in mind, the PBMs use the NCPDP database to validate a pharmacy submitting claims.

Other advice on the NPI is that you should contact your high prescribers now, as a starting point, to advise them that you will need their NPI come May 23. This way the doctor file in your pharmacy system will be ready to go, assuming your software vendor has made whatever changes are necessary to accommodate the NPI. The reason I say do it now is that while May 23 is the compliance date, some plans will be implementing sooner -- Delaware Medicaid is a case in point. Their implementation date is March 24. What I learned is that if Delaware Medicaid has an NPI on file for the prescriber, and this number is not on your claim, expect a reject. I also advise that you pay attention to any new payer sheets that arrive in your pharmacy. Check these to see what number to use if a prescriber does not have an NPI come May 23. Also, be sure you are getting the prescriber's individual NPI and not the clinic's.

Now for CMI. This is the year the FDA is scheduled to do another shoppers survey to see if patient education leaflets measure up to the Keystone criteria. These criteria to improve readability call for use of 10-point type as a minimum, short line length of 40 characters as the ideal, and more white space between sections of the leaflets. Make sure the leaflets you are handing out do not truncate the text in mid-sentence for lack of space. The consumer groups have put pressure on the FDA to enforce the CMI regs. If this year's survey turns up more of the same, then the industry could be faced with federal action, meaning the likelihood of MedGuides for every drug. This is not something that we want to see happen. You know the problems associated with the current MedGuides.

So for 2007, I see NPI and CMI as two priorities for pharmacy.

William A. Lockwood, Jr.
Chairman/Publisher