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Back  RFI # 547: NPI with EIN and SSN

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Submitter

Kelly Butler

Description

Is it appropriate for a provider to submit both an EIN and an SSN in the REF segment when NPI is present in the NM109? The Billing Provider loop uses the word "OR" in the IG note, but does not specifically preclude the use of both. In addition, the IG note at the Rendering Provider loop makes no mention of requirements for EIN or SSN when NPI is used. We have submitters sending both at both levels and would like workgroup guidance on the appropriateness of that interpretation of the IG.

Response

When sending an SSN or EIN as a secondary identifier, it must be the appropriate number for the provider entity that is identified in the corresponding NM1. If that provider is an individual person, the secondary REF can be that individual person's SSN. If the provider entity is a group, organization, or other non-person entity including a one-person legal entity, the secondary REF can be that entity's EIN. It does not make sense for the same entity to have both an SSN and EIN, it must be one or the other. Sending both is invalid because they would be identifying two entities, one an individual person (SSN) and one a non-person (EIN).
Submission 4/13/2007
Status Date 6/18/2007
Status F - Final
Primary References
Document 004010X098A1
SectionHeader
Page87
Set ID*
Table2
Loop2010AA