The compliance date for the National Provider Identifier (NPI) for all HIPAA-covered entities except small health plans was May 23, 2007 (small health plans have until May 23, 2008 to comply). Last year CMS announced that it was deferring imposition of sanctions for noncompliance through May 23, 2008 for covered entities that deployed contingency plans to facilitate the compliance of their trading partners. On May 24, 2008, CMS will lift its enforcement-leniency policy and implement enforcement actions in response to identified violations.