The National Provider Identifier Subpart Enumeration
How Many Organizational Type 2 NPIs Will
Your Practice Need?
Provider practices may obtain more than one Organizational Type 2 NPI
if they meet certain criteria. This is known as subpart enumeration.
What Is A Subpart?
According to the NPI regulations, to be eligible for subpart enumeration, the entity:
- Must be a component of the organizational health care provider;
- Is not a separate legal entity from the organization;
- Must furnish health care;
- May or may not conduct one or more HIPAA transactions, but needs to be identified in HIPAA transactions.
Your practice may be eligible for subpart enumeration if components have a different name, tax ID number, address (down to the zip code) or taxonomy (specialty) code. The NPI enumerator will evaluate the information in the organizational Type 2 application to determine if subpart enumeration criteria are met.
It is the responsibility of each organization to determine its subpart enumeration strategy. By regulation, payers cannot tell providers how they should enumerate themselves. To achieve administrative simplification, providers should develop an enumeration strategy that can be used for all payers. Administrative simplification is unlikely to occur if practices enumerate subparts that mirror existing provider numbers.
The information that follows is intended to be used as a guide in determining whether an organization should obtain more than one organizational Type 2 NPI, and enumerate its subparts.
How to Determine If a Subpart Needs
an NPI
If your organization meets the subpart criteria identified above, you
will need to determine if these subparts should obtain NPIs. Remember,
there are regulatory responsibilities associated with obtaining an NPI.
Therefore, careful consideration should be given to subpart enumeration.
- Does the subpart conduct its own HIPAA standard transactions?
For example, a group practice that has multiple locations, and bills claims electronically at each individual location, by regulation, must obtain a Type 2 NPI for each location conducting those transactions. However, a group practice that bills claims electronically from only one central location would not need to enumerate subparts; it would obtain only one organizational Type 2 NPI.
- Do existing Federal regulations require the subpart
to be uniquely identified in HIPAA standard transactions?
For example, Medicare regulations require DME providers to obtain an organizational Type 2 NPI for each supplier location.
- Does the subpart have a unique taxonomy or specialty
code apart from the organization?
The taxonomy or specialty code of a subpart may contractually drive payer reimbursement. Payers may be unable to identify the need to pay for services at a different level without subpart enumeration. An example of this might be a hospital clinic that is contracted under a different taxonomy code than the hospital, and therefore needs to enumerate as a subpart in order to receive proper reimbursement for its services. Subpart enumeration may not be necessary if the taxonomy or specialty code is included on the claim. Consult with payers directly if this will affect your practice to determine the most appropriate solution.
For more information on subpart enumeration, please refer to the Medicare
Subpart Presentation 
. See also NDEDIC-NPI Facts,
How Do I Apply For My Practice? 
which contains an illustration of
practice arrangements and enumeration scenarios. While this document was
prepared for dentists, the information in this section is pertinent to
all providers.
Keep in Mind . . .
- Payers may be able to use information contained in
the electronic claim file to successfully crosswalk the NPI to the current
provider identifier. This may eliminate the need to enumerate subparts.
See the Guide to NPI Data on the Revised
CMS-1500 and the Electronic Claim File (837P) for additional information.
- A future version of the 837P electronic claim will require providers to use the same NPIs for all transactions and all payers. This will facilitate electronic Coordination of Benefits and reduce manual secondary billing. Refrain from obtaining multiple NPIs to meet the requirements of an individual payer.
- It may benefit you to analyze how many provider identifiers
the major payers have issued to your practice. For example, what data
or information distinguishes these provider identifiers from each other?
Do these identifiers affect reimbursement? If so, will additional information
need to be captured on your electronic claim file to insure proper reimbursement?
See the Guide to NPI Data on the Revised
CMS-1500 and the Electronic Claim File (837P) for additional information.
