RFI Browser

Back  RFI # 1989: 837 2310B Rendering Provider

Formal vs. Informal Help Informal Formal

Submitter

Tia Martinez

Description

The 837I/P guide states that the Rendering Provider Loop is required when different than the Billing Provider. RFI #1531 states the difference includes both name and Id. In the situations where staff members provide services under a group NPI (e.g. Case Management services), the billing provider name would be the organization and the billing provider npi would be the group npi. Because the service was rendered by a staff member of the group, and their name is different than the group, would the staff member's name be expected in Loop 2310B? If so, with or without an associated NPI? If an NPI were included, it would be the same as the billing provider NPI and it was my understanding that was not a valid way to report in the 837 I/P. Or would the rendering provider loop be omitted because the staff member is a part of the billing entity and they do not qualify for their own NPI?

Submitter Assigned Keywords

5010 837 2310B

Response

For the purposes of the response, the term “staff members” as used in the request is interpreted to be staff that are not defined as providers and are not identifible on a claim (for example lab technician etc).

The situational rule for the Rendering Provider loop (2310B in the 837P guide 005010X222) reads "Required when the Rendering Provider information is different than that carried in Loop ID-2010AA - Billing Provider."

The basic understanding is that you must be dealing with a "rendering provider", and not just a person that is performing a service. A person doesn't become a provider just by being employed by a billing provider. Staff of a billing provider that are not providers are not separately identifiable, don't have assigned identifiers, and are not considered to be rendering providers to be reported in loop 2310B. When those staff members perform the service, the guide doesn't contain any guidance for population of the 2310B loop.

Recommendation

There are business conventions that as the service is being done by a technician (for example) within a group practice, the rendering provider reported is the provider who is overseeing the care of the patient.

If a laboratory or ambulance provider was the billing provider, then the rendering provider loop would not be used.
Submission 10/30/2014
Status Date 3/30/2015
Status F - Final
Primary References
Document 005010X222A1
Section2.4
Set ID837
Loop2310B