Author Topic: Multiple Tax IDs for the same Group NPI?  (Read 2562 times)

MGPLTO

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Multiple Tax IDs for the same Group NPI?
« on: March 28, 2014, 04:07:40 PM »
Is this scenaio possible? Can one group NPI have mulitple tax ids? For example the same NPI 12345XXXXX is used for two practice names of each have different taxt ids. Shouldn't each of the practice or tax id have its own specific NPI?


RichardP

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Re: Multiple Tax IDs for the same Group NPI?
« Reply #1 on: March 28, 2014, 05:35:44 PM »
1.  You use the terms "Group" and "Practice Name".  The term "Group" has an official and distinct set of criteria to be met before CMS / Medicare will consider a collection of doctors a group.  For billing purposes, you are not a group just because you call yourself one.  That constraint does not apply to a Practice.  But Point 3 below applies, whether one is a legitimate Group or a simple Practice.

2.  In order for a Group to obtain a TIN, they must be legally organized as a group, must meet CMS's definition of Group, and must have a single TIN (or Employer ID Number (EIN)) assigned to the group.  With these conditions met, the Group, as a legal entity, becomes the billing entity.

3.  As the billing entity, the Group may obtain one Type 2 NPI Number (who gets paid).  In the great database in the sky, the TIN/EIN and the Type 2 NPI Number are linked.  That happens as part of the process of obtaining NPI Numbers Types 1 and 2.  If you submit a TIN/EIN and a Type 2 NPI Number with a billing, and if those two numbers are not linked in that database, the billing will be rejected.  That is how it is supposed to work, and how it usually works.

4.  When I was first getting up to speed on this topic a number of years ago, CMS guidelines said it was desireable for a large billing entity with multiple sub-units beneath it to obtain NPI Numbers for those sub-units - so each sub-unit could be its own billing entity (useful for accounting purposes).  But I know a number of things have changed pertaining to NPI Numbers since then, and so I would hesitate to speculate about whether one Tax ID Number can "own" multiple NPI Numbers now.  A Health Care attorney in your State could set you straight on that one.  But the reality of Point 3 makes it unlikely that anyone could get away with one NPI Number attached to multiple Taxpayer IDs.

However, systems are not perfect, and perhaps someone has fallen through the cracks.  If so, the reality of Point 3 will eventually catch up to them - since that is why CMS put that system in place - to identify and dismantle situations such as you describe.
« Last Edit: March 28, 2014, 05:40:41 PM by RichardP »