Effective January 1, 2016, the existing requirement under the Center for Medicare & Medicaid Services (CMS) regulation §423.120(c)(5)(iii)(B)(2) which states that Part D Benefit Sponsors must pay a claim even when the pharmacy does not correct the National Provider Identifier (NPI) or confirm that it is active and valid will no longer be applicable.

CMS guidance states that Part D sponsors must ensure that lack of an active valid prescriber NPI does not unreasonably delay a beneficiary’s access to a covered Part D drug by taking the following steps: