Question: Do medical students, interns, and residents need National Provider Identifiers (NPIs)?
Answer : All health care providers are eligible for NPIs and may apply for them. Because medical students, interns, residents, and fellows are health care providers, they are eligible for NPIs. If they do not transmit any health data in connection with a transaction for which the Secretary of Health and Human Services has adopted a standard, they are not “covered” health care providers under HIPAA and are not required by the NPI Final Rule to obtain NPIs.
If they do, however, they would be covered health care providers and they must get NPIs. If interns or residents prescribe medications for patients whose prescriptions are filled by pharmacies, refer patients to other health care providers, or order tests for patients from other health care providers, those pharmacies and other health care providers will need to identify them as prescribers or as providers who referred patients or who ordered tests for patients in the claims transactions that they submit to health plans.
Health plans may require that the NPI be used in those claims to identify the prescriber, the referring provider, and the ordering provider. Therefore, while the NPI Final Rule might not require these providers to obtain NPIs, it may be necessary for them to have NPIs in order for the pharmacies and providers described in the scenarios above to be reimbursed by health plans.
Answer : All health care providers are eligible for NPIs and may apply for them. Because medical students, interns, residents, and fellows are health care providers, they are eligible for NPIs. If they do not transmit any health data in connection with a transaction for which the Secretary of Health and Human Services has adopted a standard, they are not “covered” health care providers under HIPAA and are not required by the NPI Final Rule to obtain NPIs.
If they do, however, they would be covered health care providers and they must get NPIs. If interns or residents prescribe medications for patients whose prescriptions are filled by pharmacies, refer patients to other health care providers, or order tests for patients from other health care providers, those pharmacies and other health care providers will need to identify them as prescribers or as providers who referred patients or who ordered tests for patients in the claims transactions that they submit to health plans.
Health plans may require that the NPI be used in those claims to identify the prescriber, the referring provider, and the ordering provider. Therefore, while the NPI Final Rule might not require these providers to obtain NPIs, it may be necessary for them to have NPIs in order for the pharmacies and providers described in the scenarios above to be reimbursed by health plans.
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