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Back  RFI # 285: Follow-up to HIR 284 - NEI

Formal vs. Informal Help Informal Formal

Submitter

Rick Berg

Description

My deepest apologies because after reading your response I realized I gave you the wrong loop. I should have been asking about loop 1000B (Premium Payor's Name) in the 820 where the value "65" is listed in the 4010 guide. It states it shall be used when the National Employer Id is mandated. The value 65 is not listed in the 5010 version that's out for public review so I'm assuming it was not mandated.

The submitter requesting that we accept "65" and is pointing to a final rule from CMS regarding EIN
DEPARTMENT OF HEALTH AND HUMAN SERVICES Office of the Secretary
45 CFR Parts 160 and 162 [CMS–0047–F] RIN 0938–AI59
Health Insurance Reform: Standard Unique Employer Identifier

They defend that this is an item that is open to interpretation and that we should accept it. Again I'm sorry for the earlier mistake on the loop and I'm hoping you can tell me if we should accept "65" in N103 of loop 1000B on the 820. Thank you

Submitter Assigned Keywords

National Employer Identification

Response

We recognize that we have a technical error, where the Implementation Guide requires the use code 65 once the National Employer Identifier is adopted. But, code 65 was never added to the standard. Consequently, use of the code 65 is not permissible, without violating the standard. Since the standard and the Implementation Guide both support code FI, we recommend that as a work around solution, code FI should be used to identify the new National Employer Identifier. This is not all that illogical, since FI is the code for the Employer Tax Identifier, and as it turns out the National Employer Identifier is also the Federal Tax Identifier.
Submission 7/19/2005
Status Date 9/1/2005
Status F - Final
Primary References
Document 004010X061
SectionHeader
Page63
Set IDNM103
Loop1000B