Corporate Compliance

CMS issues new guidance on subpart NPIs

Compliance Monitor, February 8, 2006

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A covered healthcare organization's subpart must obtain a national provider identifier (NPI) if it conducts HIPAA standard transactions separately from its parent organization, according to a new document on the CMS Web site. A subpart is a unit that would otherwise meet the tests for being a covered healthcare provider if considered apart from its parent organization.

The six-page paper provides guidance to organizations determining whether they should designate subpart NPIs. For example, according to CMS, a subpart

  • may or may not be in the same location as the organization of which it is a part
  • may or may not have a taxonomy (i.e., Medicare specialty) that is the same as the organization of which it is a part
  • is not a separate legal entity, but is a part of a covered organization healthcare provider that is a legal entity
  • furnishes healthcare

Click here to view CMS' NPI guidance.



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