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Do Medical Students, Interns, and Residents Need National Provider Identifiers?

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By Morgan Passiment Director of Information Resources Outreach and Liaison, AAMC

The National Provider Identifier (NPI) is a Health Insurance Portability and Accountability Act (HIPAA) Administrative Simplification Standard. The NPI is a unique identification number for covered health care providers.

All health care providers are eligible for NPIs and may apply for them. Because medical students, interns, residents and fellow 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 test 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 other providers to be reimbursed by health plans.

A Healthcare Provider Taxonomy Code for classifying medical students, and interns and residents who are not yet licensed (based on state licensing requirements), is available for use: Student Health Care (390200000X). The code is defined as follows: An individual who is enrolled in an organized health care education/training program leading to a degree, certification, registration, and/or licensure to provide health care. Medical students, interns, and residents who are not licensed should select the Student, Health Care code when applying for NPIs. Once licensed as a physician, the physician should update his/her data in the National Plan and Provider Enumeration System (NPPES) by submitting a change in the Healthcare Provider Taxonomy Code to reflect the change in status from medical student to physician.

Centers for Medicare & Medicaid Services NPI Resources

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