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American Association of Oral and Maxillofacial Surgeons

Practice Management & Allied Staff News & Materials

NPI Guidelines for Practices with Multiple Locations

March 18th, 2013

When a practice has multiple locations they often operate independently of each other and usually do their own billing. Many health plans consider each separate physical location to be a health care provider itself; and many of these health plans, including Medicare, reimburse for these items based on the geographic location where the items are dispensed to patients and not on the geographic location of the corporate headquarters.

When applying for an NPI, there are two different entity types to choose from. The first is Entity Type 1 that would be assigned to an individual who provides health care services using their individual SSN, and the second is an Entity Type 2 assigned for an organization providing health care services using their organization's Employer Identification Number (EIN). The NPI final rule, released in 2004 states that a designated health care component may in essence be assigned multiple NPIs if the health care component is made up of multiple health care providers at separate locations or "subparts". Therefore, if each practice location or "subpart" has its own EIN, then each location would require its own Type 2 NPI. However If each practice site or "subpart" operates under the same EIN, there would be certain criteria to determine if each "subpart" should have its own NPI. The separate locations generally:

  • operate independently from the "parent "organization
  • conduct its own HIPAA standard transactions (are assigned their own unique Entity Type 2 NPI)
  • certified by the State separately from the "parent" organization

Every OMS/practice is responsible for determining the number of NPIs necessary, therefore AAOMS encourages all members to consult with a practice attorney, accountant, or consultant when applying for NPI's to ensure that claims processing is not interrupted.