NPI Numbers > NPI Numbers

multilpe npi numbers and billing


I am working with  facility that has a very unique setup.  The hospital has an NPI number and their Geriatric Psychiatric unit has an NPI number.  Both facilities are using the same EMR and the Geriatric Psychiatric patients are coded as medical inpatients, same as the hospital inpatients.   According to the site, they  are billed the same.  So my question is can a facility bill under two NPI numbers for the same stay type? 

Do they have two EINs?


--- Quote from: Michele on August 06, 2014, 08:07:54 AM ---Do they have two EINs?

--- End quote ---

This is my question too. Our clinics have 2 EINS and 2 NPI's. One of the EIN/NPI combinations is a specific type of Medicare-certified rehabilitation clinic, the other is a regular medical clinic. Most of our providers are credentialed under both and can choose which to bill under depending on the patient's needs and situation.

Remember - the Type 2 NPI Number is for who gets paid.  The Type 1 NPI Number is for who does the work.  An answer to your question is at Point 8(d) below.  But it will make sense only if you understand all the rest of these points.

1.  A non-human legal entity can never "do the work".  Therefore, Type 1 NPI Numbers are always assigned to humans.

2.  Type 2 NPI Numbers are always assigned to the billing entity - which is always non-human.

3.  A human has a Taxpayer ID Number (TIN) / Social Security Number.  A human can also have an Employer ID Number (EIN).  But this is misleading, because that EIN is not really attached to the human.  It is attached to the human's business (can't have an EIN unless you employ people; therefore, a business).

4.  An organization can only have an Employer ID Number (EIN).  Organizations can never have Social Security Numbers.

5.  The Type 1 Number is assigned to who did the work - which can only ever be a human with a Social Security Number.

6.  The Type 2 Number is assigned to who gets paid - the billing entity - which can only ever be a business with an Employer ID Number.  That business can be a large organization, or a single provider who has obtained an EIN and has listed himself as the sole employee of his business.

7.  In the Medicare database, only one Type 1 NPI Number (who did the work) can be associated with a given Social Security Number (SSN).  Only one Type 2 NPI Number (who gets paid) can be associated with a given Employer Identification Number (EIN).  That is the entire point of the NPI Number and the database - to force this very issue.  I don't think they are comletely there yet, but they are close.

8.  Now - consider organizations:

  a.  A person and an organization smaller than a certain size only needs one billing entity.  Therefore, only one EIN and Type 2 NPI Number.

  b.  Organizations larger than a certain size often break themselves into multiple billing entities.  Each billing entity could have its own EIN and therefore its own Type 2 NPI Number (who gets paid).

  c.  Only one EIN may have a Type 2 NPI Number attached to it.

  d.  But one organization (with its own EIN and Type 2 NPI Number) may own a number of sub-units, each of which has its own EIN and Type 2 NPI Number.

This is the way it was when the NPI Number system was first being established, based on my research of the issue then.  We've had a similar discussion here a while back and somone pointed out that they thought Point 8d was not true.  I know that Point 8d was true when the NPI systems was first being implemented.  I also know that Medicare has tweaked the NPI Number system since it was first implemented.  So - all I will say is, if it is important, check with a HealthCare Attorney who knows the laws for your State.

9.  An example of Point 8(d) that I am familiar with is the distinction between a Physician Office Lab (POL) and a Clinical Lab.  Medicare has changed its rules recently, but has grandfathered POLs established long ago.  Under the grandfathered exception, one doctor must own the Physician Office Lab, but up to four other physicians (five total) can use it.  Each doctor bills his own lab charges under his own NPI Number (Type 1 or Type 2, depending on how his business is set up).  But if the sixth doctor wants to use the lab, it must be turned into a Clinical Lab - and become a billing entity on its own behalf, with its own EIN and its own Type 2 NPI Number.  At this point, the original doctor may still "own" the lab (depending on State law), but nobody using the lab can continue to bill for its services under their own NPI Number.  The lab must do its own billing, with its own EIN and associated Type 2 NPI Number.


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