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Ethical, legal or illegal

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RichardP:
tallmanusa - I'm not clear on what you are saying.  So, to clarify - as long as you have the following paragraph correct, then we are good here.

When you sign a contract, it should be signed with the billing entity.  That is, it should be signed with the owner of the Type 2 NPI Number that goes in Box 33a of the CMS 1500 Form.  If the owner of that NPI is a legal entity rather than a natural person (Doctors Group, Corporation, LLC, etc.), your contract should be signed by whoever is authorized to bind that legal entity in contracts.  All billing work from that entity that you submit for payment should have the legal entity's Type 2 NPI Number (who gets paid) in Box 33a of the CMS Form 1500.  However, you should also be given the Type 1 NPI Number of the doctor who actually did the work.  For Medicare billing, and maybe other payers, this Type 1 NPI Number is required to be in Box 24J of the CMS 1500 Form.

Merry:
A  Provider’s main site NPI  number may  not  be  assigned to  any  other  Provider site. >>

So I would think that the suggested idea would not work. When you say reassignment, you are saying changing his address info. His NPI is now connected to one location and it is in process to be moved to another location. Right? So, this is a change of address that needs to be done through the correct channels..unless I am misunderstanding.

Merry

RichardP:
Merry - I'm not certain what you are saying or asking.  We are not discussing assigning or re-assigning NPI Numbers in this thread.

A doctor in private practice may have multiple locations where he does business on his own behalf.  That doctor uses his Type 1 and Type 2 NPI Numbers at all his business locations.  These locations need to be registered with Medicare and other carriers.  Assuming that patients have assigned their payments to the doctor, payment for work at any of these registered facilities would go to the address connected to the Type 2 (who gets paid) NPI number on file with CMS

A doctor can hire himself out to, for instance, a doctors group that is a legitimate legal entity.  This legal entity would be the billing entity and would have its own Type 2 NPI Number (who gets paid) - which is used in Box 33a for all billing done on behalf of the work done by that doctors group.  That billing entity would also need to acquire Type 1 NPI Numbers (who did the work) for all hirelings / owners who do work for that doctors group.

So - Merry, assume you are a doctor.  You could do work at you own place(s) of business and bill for that work using your own Type 2 (who gets paid) NPI Number and Type 1 (who did the work) NPI Number.  You could also do work at the doctors group that has hired you.  That doctors group would pay you a salary.  They would also bill for the work you did by using their Type 2 (who gets paid) NPI Number and your Type 1 (who did the work) NPI Number that they obtained for you as an employee / owner of that legal entity.  You could theoretically work for a number of different doctors groups - and each would be required to obtain a Type 1 NPI Number for you - to use when billing for the work you did at that particular doctors group.  So - no re-assignment of NPI Numbers anywhere.

Each doctors group / legal entity for which you do work, and which is also the billing entity, would need to add you as an owner / employee of that entity to the list they have on file with Medicare, and other carriers, depending on each carrier's requirements.

Now consider the assignment of Medicare payments for the Medicare patients you have in your private practice.  To keep things simple here, the Medicare payments are actually assigned to the Type 2 NPI Number (who gets paid) and the address info connected to that NPI Number at CMS.  If you get hired by a doctors group but you wish the assignment of payment for work done in your private practice to still go to your Type 2 NPI Number, you would do nothing.  But if a condition of employment by the doctors group is that you transfer assignment of Medicare payment to them as the billing entity, then you (in conjunction with your patients) would request that Medicare change the assignment of your patients' payments to the Type 2 NPI Number (who gets paid) of the doctors group.  That process can take up to six weeks to complete.

This is an issue only if patients from your private practice are going to come to the doctors group that has hired you.  If you are only going to see patients at the doctors group that have already assigned their payment to the medical group, transfer of assignment is not an issue.

Merry, I'm assuming you already know this??  I'm writing for those who may not know.  And, as I am trying to stay general rather than specific here, and as I don't know everything, I may have left out something important.  I leave it to others to point out the pieces I may have missed or should have included in this discussion.

Merry:
The word reassigning was used. I commented more on the words used. I think its more an address change.

dekenn:
I also thought that as far as NPI numbers, each physician has one and only one NPI number and that is his/her OWN NPI number. THey do not get another one depending on who they work for, it just gets billed under the employers type 2 npi.

When you go to the NPI registry, each physician only has 1 NPI, not one for each place he works.

Also, just to clarify, if a physician is a sole proprietor and is not billing for anyone else, he only needs one NPI, his own personal NPI. He does not need a type 2 NPI if he is not incorporated.

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