Robbi, Can we agree on some terminology consistent with the HIPAA Implementation Guides first?
- SSN is a number assigned by the SSA to individual people - EIN is a number assigned by the IRS to employers, as discussed in the Final Rule. - TIN (or TaxID) is a number used for tax reporting purposes. As the final rule explains, it can be either the SSN, EIN, or an IRS assigned TIN. - NPI will be a number assigned by somebody (CMS?) under HIPAA to identify providers. - Today most providers are identified in two different forms: a) a payer assigned (PIN) Provider ID Number, and b) a TIN used for the 1099. Most of the time the TIN is the EIN, but some times it is the SSN, at the provider's choice. The HIPAA transactions have qualifiers for all these numbers. Typically in NM108, N103, or REF01. Some times you have the choice of NPI, SSN, EIN, and TIN. Some times it is a more restricted list of choices. Now to your question. It seems that the Final Rule on Employer ID is not completely clear whether the standard adopted under HIPAA applies every time you are using an EIN, or it only applies when you are using an EIN to identify an "Employer" in the capability of "Employer". Certainly you can identify a provider by the provider name, or by the provider address and telephone number, or by the provider driver's license number, or by the provider's SSN, or by the provider's UPIN, or by the provider's DEA number, or by the provider's state license number, or by the provider's EIN, or by the provider's NPI in the future. Under HIPAA several of these are practical choices (SSN, UPIN, DEA, State License, EIN, NPI) for different kinds of providers. So, you have a choice. The preamble of the final rule seems to indicate that if your choice is to use the EIN, then you must use the HIPAA standard for the EIN. But the language of the regulation itself does not make this clear. The problem is that until the NPI is issued, there is not much of a choice in some cases. If you look carefully you will see that the 837 gives a "choice" to identify the primary provider ID between SSN, NPI, or EIN. Practical reality says that until the NPI is issued most people will use the EIN as the only real "choice". Then look at the 835 and the EIN is not a choice, the "choice" in the 835 is the TIN instead. So, this introduces some unpredictability: If a provider sends the EIN in the claim (with the hyphen) and the payer strips the hyphen for internal processing, is the payer going to re-insert the hyphen when sending the 835? Since there is no standard for TIN, some payers will insert the hyphen for the 835 TIN and other payers will not. Here is some unsolicited practical advice: - If you are sending an EIN, and the qualifier says it is an EIN, make sure you send the hyphen in the data. - If you are receiving an EIN, allow for the hyphen to be either absent or present. Accept it both ways. Normalize the data yourself to accommodate what your system needs internally, but do not force your trading partners to go one way or another. In other words, be flexible. - If you are receiving a TIN, allow the same sort of flexibility, as some will send the hyphen, and others won't. - If you are sending a TIN, and you happen to know that it is an EIN, then... this needs to be addressed by SNIP. My recommendation would be to not send punctuation, to be consistent with current business practice, but the best would be to have some sort of industry consensus on this one. The ball is in the court. Who wants to pick it up? Kepa On Friday 28 June 2002 07:57 pm, Robbi McClane wrote: > I am curious as to whether others are unsure of how to code an Employer's Identification Number when it is not identified as the "National Employer Identifier". > > In other words does the wording regarding use of the "-" in the latest final ruling cover only identifiers when qualified by a code indicating that it is the National Employer Identifier (e.g. ZZ in some transactions) or does it also extend to when the qualifier of "24" or "EI" is used even though these qualifiers are for Employer's Identification Number and not the National Employer Identifier.... > > Bottom line is, I'm trying to evaluate when mapping Employer Identification Numbers do I need to > 1) allow occurence of a "-" > 2) force occurence of a "-", which then means that I also have to worry about stripping out the hyphen for both EIN and NEIN when mapping to my internal format... ********************************************************************** To be removed from this list, send a message to: [EMAIL PROTECTED] Please note that it may take up to 72 hours to process your request. ====================================================== The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. Posting of advertisements or other commercial use of this listserv is specifically prohibited.
