Unique Identifier Rule Can Be Confusing
By Greg Freeman
HIPAA’s Unique Identifier Rule mandates the use of standardized codes to provide unique identification of healthcare organizations, employees, and patients in an effort to enhance efficiency and security. The requirements and use of the codes can be confusing.
The unique identifier rule was part of the administrative simplification part of HIPAA, explains Amy M. Magnano, JD, partner with the Morgan Lewis law firm in Seattle. The goal was to make the identification process more efficient by ensuring that patients, health plans, and providers would all have a unique identifier to use in standard transactions, she explains.
“The thing to know about it, though, is, although the rule originally envisioned two unique identifiers for four categories, ultimately, now there are two categories currently in existence,” she says. “So, as a healthcare entity, you have to have an Employer Identification Number [EIN], which is actually something that came out of the tax code. So, this is where this gets kind of complicated, because you have to have an EIN to submit standard transactions as a healthcare entity.
The National Provider Identifiers [NPI] is a unique 10-digit identification number covered entities use with standard HIPAA electronic transactions, says Henry Norwood, JD, an attorney with the Kaufman Dolowich law firm in San Francisco. One common pitfall health providers face with their NPI numbers involves locum tenens providers — a temporary provider covering at a facility for another provider who is unavailable, he notes. Should the facility bill under the normal provider’s NPI or the locum tenens provider’s NPI? The answer can vary depending on whether the patient is covered by Medicare, Medicaid, or private insurance, Norwood says.
He explains that if billing through Medicare, the facility can bill under their normal provider’s NPI if the normal provider is unavailable, the Medicare patient is seeking care from the normal provider, the locum tenens provider is paid per diem, and the locum tenens provider cannot bill under the normal provider’s NPI continuously for more than 60 days.
“Medicaid plans typically follow this same rule, but facilities should confirm with their state Medicaid rules. Private plans generally allow billing services by locum tenens providers under the normal provider’s NPI, but facilities should confirm with each patient’s plan in advance,” Norwood says. “Misusing an NPI number can cause issues ranging from billing headaches to potential fraud actions by the government, so health providers should plan to avoid issues in advance.”
Sources
- Amy M. Magnano, JD, Partner, Morgan Lewis, Seattle. Telephone: (206) 274-6451. Email: [email protected].
- Henry Norwood, JD, Kaufman Dolowich, San Francisco. Telephone: (628) 219-9814. Email: [email protected].
HIPAA’s Unique Identifier Rule mandates the use of standardized codes to provide unique identification of healthcare organizations, employees, and patients in an effort to enhance efficiency and security. The requirements and use of the codes can be confusing.
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