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Back  RFI # 678: TIN in 2310b loop

Formal vs. Informal Help Informal Formal


David Chaffee


There are certain insurance payers who are requiring a Tax ID in the 2310b loop when billing in a group format 837P 4010A1. This issue was addressed in the CMS FAQ 5816. It is stated in this FAQ 5816 that the TIN is to be used for tax purposes only and not as a legacy ID. CMS has since backed away from this FAQ and is referring this question over to the X12 Portal as an implementation issue. Can a payer require submission of a 2310B secondary ID of the TIN when the NPI is provided as the primary provider ID?

Submitter Assigned Keywords

2310b provider id


The 004010X098A1 Implementation Guide explicitly states that the tax ID intended for reporting on the 1099 is
sent in the 2010AA Billing Provider Secondary Identification REF or the 2010AB Pay to Provider Secondary Identification REF. This is expressly allowed by CMS FAQ 5816.

The 2310B Rendering Provider Secondary Identification REF is used to identify the
Rendering Provider when the primary ID NM109 is insufficient When NM109 contains the NPI, the provider is identified and reporting of additional identifiers is prohibited by CMS FAQ 5816.


Submission 8/8/2008
Status Date 2/4/2010
Status F - Final
Primary References
Document 004010X097A1
Set ID2310
Segment IDREF
Element Position02