Can a health care provider continue to use other numbers besides the NPI?

Only the National Provider Identifier (NPI) may be used for identification purposes for a covered health care provider in standard transactions. Legacy identifiers (such as the Unique Physician Identification Number (UPIN), Medicaid Provider Number, Medicare Provider Number, and others) may not be used. Where a covered health care provider must be identified in standard transactions for tax purposes, must use its Taxpayer Identifying Number as required by the implementation specifications. Health care provider identification numbers other than the NPI can be used in the internal processes and files of health plans or health care clearinghouses if they wish to continue to use those identification numbers for internal processes and files.

Who is not eligible to apply for a National Provider Identifier (NPI)?

Any entity that does not meet the definition of a “health care provider” found at 45 CFR 160.103 is not eligible to apply for an NPI. Examples of entities who do not meet that definition, but whose non-health care services may be reimbursed by certain health plans, include non-emergency transportation services, companion services, language interpretation services. In addition, billing services and health care clearinghouses are not eligible for NPIs because they do not meet the regulatory definition of “health care provider.” Other providers who are health care providers, but are not covered entities because they do not transmit information electronically using the standards adopted under HIPAA, are not required to obtain an NPI, but are not prohibited from doing so, and in some cases are encouraged to do so, as that number may be required for billing purposes by another provider to whom a referral has been made. If a non-covered health care provider obtains an NPI, it does not make him or her a covered entity.