Certification Statement for Electronic File Interchange Organizations that Submit NPI Data to the National Plan and Provider Enumeration System (CMS-10175)

Forms and Documents

Document Name	Status
Form CMS-10175 Certification Statement for Electronic File Interchange Organizations that Submit NPI Data to the National Plan and Provider Enumeration System Form and Instruction	Modified
CMS-10175 Supporting Statement_Final_.docx Supporting Statement A	2021-03-04

IC Document Collections

IC ID	Document Title	Status
43676	Certification Statement for Electronic File Interchange Organizations that Submit NPI Data to the National Plan and Provider Enumeration System Form and Instruction	Modified

ICR Details

OMB Control No: 0938-0984	ICR Reference No: 202103-0938-006
Status: Received in OIRA	Previous ICR Reference No: 201705-0938-009
Agency/Subagency: HHS/CMS	Agency Tracking No: 20493
Title: Certification Statement for Electronic File Interchange Organizations that Submit NPI Data to the National Plan and Provider Enumeration System (CMS-10175)
Type of Information Collection: Reinstatement without change of a previously approved collection	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 03/05/2021

	Requested	Previously Approved
Expiration Date	36 Months From Approved
Responses	32	0
Time Burden (Hours)	8	0
Cost Burden (Dollars)	0	0

---

Abstract: Health care providers can currently obtain a National Provider Identifier (NPI) via a paper application or over the Internet through the National Plan and Provider Enumeration System (NPPES). These applications must be submitted individually, on a per-provider basis. The Electronic File Interchange (EFI) process allows provider-designated organizations (EFIOs) to capture multiple providers' NPI application information on a single electronic file for submission to NPPES. (This process is also referred to as "bulk enumeration.") To ensure that the EFIO has the authority to act on behalf of each provider and complies with other Federal requirements, an authorized official of the EFIO must sign a certification statement and mail it to the Centers for Medicare and Medicaid Services (CMS).

---

Authorizing Statute(s): PL: Pub.L. 104 - 191 Title II Name of Law: Health Insurance Portability and Accountability Act
  

Citations for New Statutory Requirements: None

---

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

---

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 60170	09/24/2020
30-day Notice:	Federal Register Citation:	Citation Date:
	86 FR 12191	03/02/2021
Did the Agency receive public comments on this ICR? No

---

Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Certification Statement for Electronic File Interchange Organizations that Submit NPI Data to the National Plan and Provider Enumeration System	CMS-10175	EFI Certification Statement

---

ICR Summary of Burden

	Total Request	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	32	0	0	0	11	21
Annual Time Burden (Hours)	8	0	0	0	3	5
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: CMS is using more accurate data from NPPES to estimate respondents who use the Certification Statement for Electronic File Interchange Organizations (EFIOs). By doing so, we were able to accurately estimate the number of respondents from 21 to 32 respondents (+11). NPPES currently reports that the CMS-10175 is usually completed, signed and submitted by a professional, such as a chief member of the organization acting as the Authorized Representative for the organization. The CMS-10175 form is comprised of 3 pages, only one of which has minimal data fields to be completed and a certification statement to be signed. NPPES now estimates that completion of those data fields and their submission takes 15 minutes to complete. That increases the burden hour estimate by 2.75 hours (from 5.25 to 8.0 hours). Combined, the annual increase in burden hours is 2.75 (from 5.25 to 8.0 hours) and the increase in cost is $552.92 (from $938.28 to $1,491.20.). The increase in the number of respondents is 11 (from 21 to 32).

---

Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

---

Common Form ICR:  No

---

On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 03/05/2021

---