CMS has released information to help with the transition from the provider identifier used in HIPAA standard transactions to the new National Provider Identifier--specifically on the issue of organizational subparts. When healthcare provider organizations apply for an NPI, they must determine whether they have subparts that require their own NPIs. CMS defines an organizational subpart as follows: It is not a separate legal entity; it furnishes health care as defined at 45 CFR 160.103; it does not have to be at the same location as the covered organization healthcare provider; it may have a different medical specialty from the covered organization, and it conducts HIPAA transactions separately from the covered organization. For example, a hospital that owns six home health agencies operating under the tax identification number of the hospital would require seven unique NIPs if each home health agency is separately surveyed and has its own provider agreements with Medicare.
Click here to access CMS information on the electronic file interchange process, which allows an organization to apply for NPIs.
