RFI Browser

Back  RFI # 787: 5010 276 2100C Loop Tax ID

Formal vs. Informal Help Informal Formal

Submitter

Jennifer Delmont

Description

Based on the 5010 TR3 note 3 on page 49 (loop 2100C NM1 segment) it appears that providers can no longer send both a NPI and tax ID for identification (repeating loop 2100C). Is this a correct interpretation? If so, is there any guidance given to payers who are still crosswalking NPI to legacy ID when there can be one NPI with multiple different tax ID's?

Response

This issue is explicitly addressed in guide 005010X212. The note on loop 2100C NM108 code XX (NPI) reads "Required value when the National Provider ID is mandated for use and the provider is a covered health care provider under the mandate. Otherwise, one of the other listed codes must be used." Therefore, for providers covered by the NPI mandate, only the NPI can be sent as the identifier in the 2100C loop NM1 segment. The 2100C loop doesn't support any secondary IDs. So, when the NPI is sent in NM108/9 the tax ID can't be sent.

Recommendation

While it is our understanding that a single NPI is associated with a single tax ID in the NPI system, HIPAA policy questions need to be addressed to CMS directly at http://questions.cms.hhs.gov/cgi-bin/cmshhs.cfg/php/enduser/ask.php?p_prods=21,25,381
Submission 5/20/2009
Status Date 5/21/2009
Status F - Final
Primary References
Document 005010X212
Section2100C
Page49
Set IDNM1