Single-member LLC NPI type?

[katyus]

Hello-

I have a single member LLC. Is it true I need to register for both a type 1 and type 2 NPI number. If so, why? And if so, for the individual registration, so I select "no" when it asks if I am a sole proprietor? Because technically, I am not - I am technically a single member LLC.

Thanks in advance!

[Michele]

Yes you need both a type 1 and a type 2 NPI.  You need the type 1 for yourself individually as a rendering provider.  You need the type 2 for your LLC.  Since you have an LLC with an EIN and a legal business name you need an type 2 NPI for the entity.  It seems confusing since you are just one provider but when you formed the LLC you 'created' a separate entity from yourself which needs it's own NPI.  I hope that helps!

[RichardP]

An easy way to keep things straight in your head is to answer two questions:

1.  Who did the work?  (Needs a Type I NPI Number)
2.  Who gets paid?  (who is the billing entity)  (Needs a Type II NPI Number **)

Organizations are creations of the state, legal entities, but they can never do work.  Only a human can.  So Organizations can never have a Type I NPI Number (who did the work).

** With this exception:  the only way that the answer to both questions can be "me" is if you have applied for an NPI Number using your Social Security Number, and all payments for services rendered are made out to your personal, legal name.  If that is the truth in your case, then you only need a Type 1 NPI Number.  (NPI Number linked to your Social Security Number.)

If you bill using your LLC's legal name, and/or you receive payment made out to your LLC's legal name, then your LLC is the billing entity, the one who gets paid (Question 2 above) - and therefore needs it's own, Type II, NPI Number.  (NPI Number linked to your orgnization's EIN.)

The thing that trips people up is the distinction between sole proprietor (doing business in your own name, using your own SSN, having created no organization) and a sole practitioner or solo practitioner (having obtained an EIN, and doing business in the name of your organization).  See the top of Page 5 at this link: [edit: see also the bottom of Page 4]

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/NPIBooklet.pdf

[dekenn]

Actually, you can be a sole proprietor with an EIN and a "doing business as" name and still have a Type 1 NPI. I believe the difference is that you are not incorporated (LLC, corporation, partnership, etc)  in any way. Even a sole proprietor needs an EIN in order to pay employees and submit payroll taxes for those employees and when you register for that, you can create a "doing business as" name without incorporating. It's just a business, not a corporation.
Maybe it depends on what state you're in, we are in NJ and that is how we are set up.

[katyus]

Thanks everyone! I am in Connecticut - anyone know how it's set up here?

[katyus]

Another question - since I need to apply for both types of NPIs, can I do this online as a single application or will it be 2 separate online applications?

[RichardP]

Actually, you can be a sole proprietor with an EIN and a "doing business as" name and still have a Type 1 NPI. I believe the difference is that you are not incorporated (LLC, corporation, partnership, etc)  in any way. Even a sole proprietor needs an EIN in order to pay employees and submit payroll taxes for those employees and when you register for that, you can create a "doing business as" name without incorporating. It's just a business, not a corporation.
Maybe it depends on what state you're in, we are in NJ and that is how we are set up.

That is the point made in the CMS link I provided.  The distinction is based on who gets paid: the human person or the organization.  To quote (from top of Page 5):

National Provider Identifier - What You Need to Know

As a sole proprietor, you may receive only one NPI, just like any other individual. For
example, if a physician is a sole proprietor, the physician may receive only one NPI
(the individual’s NPI). The following factors do not affect whether a sole proprietor is an
Entity Type 1:

Number of different office locations;
Whether you have employees; and
Whether the Internal Revenue Service (IRS) issued an EIN to you so your employees’
W-2 forms can reflect the EIN instead of your Taxpayer Identification Number (which is
your SSN).

NOTE:  A sole proprietor is not an incorporated individual because the sole proprietor did
not form a corporation. If you are a sole practitioner or solo practitioner, it does not necessarily mean you are a sole proprietor, and vice versa.

From the bottom of Page 4:  Individual health care providers may receive NPIs as Entity Type 1. As a sole proprietor, you must apply for the NPI using your own Social Security Number (SSN), not an Employer Identification Number (EIN) even if you have an EIN.

[RichardP]

Another question - since I need to apply for both types of NPIs, can I do this online as a single application or will it be 2 separate online applications?

Curiousity is a useful attribute.

Page 6 of the link I provided answers your questions.  But here you go:

https://nppes.cms.hhs.gov/NPPES/Welcome.do
Online:

https://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/downloads/CMS10114.pdf
Print and mail in.  Instructions provided

Not trying to be snarky here - but you really need to learn your own way around this issue.  It will be with you for a long time.  Come back with questions, but do your own research as well.  That would include scanning through links provided in response to your questions.

[Michele]

NPIs are national so the rules are the same in all states.  LLC is an organization and needs a separate type 2 NPI. 

[rballinger1]

You can register online for both NPI numbers, but you'll have to register separately, once as the individual, and then create an user and register for the LLC.

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