The ABCs of NPIs and DEA Registration Numbers

We sometimes hear from prescribing veterinarians with concerns about pharmacies asking for Drug Enforcement Administration (DEA) registration numbers, even for non-controlled substance prescriptions. Veterinarians want to know whether they should be giving out their DEA registration number, and whether they need an “NPI” number to prescribe, or whether they can just give their state veterinary license number?

The AVMA agrees with the Drug Enforcement Administration (DEA) that DEA registration numbers should not be used solely as identifier numbers. Since 2011 we have advocated our policy on this topic to pharmacies about using identifier numbers appropriately. Our discussions with nationwide pharmacy groups are ongoing, but so far we are encouraged that pharmacies appear to be increasingly asking for alternative identifier numbers.

Veterinarians on two of AVMA’s governance groups – the Council on Biologic and Therapeutic Agents and its Clinical Practitioners Advisory Committee - have found that state license numbers are the least burdensome to use. But AVMA has also found that pharmacies – many of which are human-oriented – prefer National Provider Identifier (NPI) numbers because they are needed for human third-party payer purposes, and because they are integral to the electronic prescribing systems that are becoming more prominent in human medicine. NPI numbers seem to be here to stay. Fortunately, they’re free to obtain, and based on what some of our COBTA/CPAC practitioners and staff found, it takes about 5-15 minutes to apply for one.

So how does it work to get an NPI number? Prescribers can apply on the National Plan and Provider Enumeration System website. Login information is required, as well as name and contact information, social security number, and other identifier numbers including state license numbers. (Note that in the Taxonomy section of the application, you can select that you are an “other” service provider, under which “veterinarian” is an option.)

Veterinarians can elect to give their state license numbers preferentially, but might find an NPI number to be more easily accepted by a pharmacy. Check state rules to ensure veterinarians are not required to have NPI numbers. As our discussions with pharmacy stakeholders continue, stay tuned for updates from AVMA.

13 thoughts on “The ABCs of NPIs and DEA Registration Numbers

    • We certainly do have an update, Dr. Kidd. We learned from the US Department of Health and Human Services (DHHS) that veterinarians are in fact not eligible to obtain NPIs. We were able to post an update via a blog post about this (my apologies the post did not come up in your search): http://atwork.avma.org/2013/08/06/new-federal-guidance-npi-numbers-not-for-veterinarians/. The HHS recommends veterinarians not only deactivate their NPIs, but to also note that “any entity that insists veterinarians obtain an NPI are attempting to require veterinarians to obtain NPIs fraudulently.” Likewise we continue to have conversations with various pharmacy stakeholders to underscore DHHS’ guidance, as well as the DEA’s contention that DEA registration numbers are not to be used solely as identifier numbers. Should pharmacy entities seek relevant credentials when they receive a prescription from a veterinarian, state veterinary license numbers could be helpful. Thanks for reaching out and I hope you find this additional information helpful. Let us know if you have any additional observations or questions.

  1. As an update, we have just heard back from federal personnel with the Department of Health and Human Services (DHHS) who advised that due to the poor fit for various individuals (such as veterinarians) with NPI rules, the DHHS recently developed an alternative nationwide identifier number, which I will be receiving more information on soon. In the interim, DHHS staff advised they plan to discuss further possible guidance for veterinarians, both for veterinarians who have already procured NPI numbers, and for veterinarians who have not but who wish to procure one for ease of communications with pharmacies. Please stay tuned for additional information as we learn more.

    • Is there any new information on this topic? In the past 2 months I have had two major national chain pharmacies insist on an NPI number. One found a work-around, and for the other I am waiting for a call back from a regional pharmacy manager. I have spent an enormous amount of time telephoning both companies corporate offices trying to find a solution.
      Thanks,
      Vanessa Davis DVM

    • We do have an update as of today. Staff are currently reaching out to federal personnel to gain insights and clarification, and in addition, the Council on Biologic and Therapeutic Agents will be receiving this information and considering any possible needed actions for AVMA to take on behalf of veterinarians. Dr. Kemp kindly shared with me the information he gained while speaking with a presenter in 2006 who, in her presentation in Washington, D.C., spoke to various practitioners (including veterinarians) not being eligible to have NPI numbers, per the Department of Health and Human Services. Staff review of the terms “health care provider” and “health care” within federal regulations fits with the presenter’s statement that Dr. Kemp shared about veterinarians’ ineligibility. However, what is also concerning is the federal inclusion of “veterinarian” as an option for a person to select in the online form (a form which was approved by another federal agency, the Office of Management and Budget, which ensures various federal forms and applications are in fact, in line with federal rules). Likewise, multiple federal personnel providing verbal NPI advice via phone have advised of the eligibility and acceptability of veterinarians to procure NPI numbers. Therefore, clarification is needed and is being sought, as is a viable identifier number for veterinarians to use when fulfilling client requests for prescriptions. Please stay tuned for updates.

    • As an update, we are currently still trying to attain a definitive answer directly from federal employees within the Department of Health and Human Services (DHHS). At the heart of the discussion is whether it’s really allowable for veterinarians to gain an NPI number since the HHS rules indicate the NPI number is specifically for “health care providers” which veterinarians are not, under the rules. Yet, the NPI application is a form that was approved by a different government group, the Office of Management and Budget, which ensure accuracy of, and approve, federal forms (and this application form specifically includes veterinarians as an option). We know that pharmacies prefer national identifier numbers such as NPI numbers, due to their software systems. The safest option for providing an identifier number to a pharmacy continues to be a veterinarian’s state license number, which we know is least burdensome on veterinarians and is an accurate, unique identifier to the veterinarian within an individual state. Please stay tuned as we inquire through various avenues with a goal of gaining a definitive answer from the federal government for members.

    • Thanks Dr. Kemp,

      You bring up some points that help underscore that National Provider Identifiers are not an ideal fit for veterinarians, because, as you point out, they were put into place to be identifier numbers associated with healthcare billing. What we know is, veterinarians want a minimally burdensome identifier number to use, as they provide prescriptions to retail pharmacies (and state license numbers would be fitting). We also know, from discussing this issue with nationwide pharmacy organizations, that state license numbers are a challenge to pharmacies and that NPI numbers are preferred by pharmacies over other numbers. It sounds like you have gained some additional insights from Department of Health and Human Services personnel that might be of interest to veterinarians. If you could share with me the best way to get in touch with you, we could discuss further.

      Lynne White-Shim

      • Email is best because of my schedule, but if you need to talk, I have a little semi-idle time at 10:40 tomorrow morning (3/5/13).

        I do understand the desire to have NPI numbers and it is driven by pharmacists’ lack of understanding of the ineligibility of veterinarians to obtain NPI numbers. I know that veterinarians have applied and been granted NPI numbers. But, since they will have attest to qualifications that they can not meet to obtain one and it is with a federal agency, there is no way I can endorse veterinarians applying for NPI numbers.

        If I had time to mount a crusade, I would first attack the home offices of the chain drug stores to get them to determine their company’s work around and spread the word. Then I would contact boards of pharmacy and state pharmacy organizations to further educate the world of retail pharmacy. Since pharmacy seems to be looking to increase the filling of prescriptions issued by veterinarians and veterinarians are ineligible for NPI numbers, pharmacy needs to bend.

  2. Dr. White-Shim
    I am very concerned about the suggestion that veterinarians should apply for NPI numbers. In order to apply for an NPI number you must attest that you meet the definition of healthcare provider as defined in 1861u of the SSA, which means that you provide healthcare to humans billable under HHS. LInda McCardel chaired the committee to examine atypical providers who are those who might not be traditional providers, but who would qualify for NPI numbers. No role of veterinarians that fit the definition was identified.

    I have been in touch with Ms McCardel several times since the question of whether veterinarians qualified for NPI numbers arose on VIN. The question was typically driven by pharmacists demanding an NPI number to fill a prescription. No changes have been made to the program and nobody, to the best of my knowledge, has identified any function of veterinarians that would qualify them for an NPI number.

    The simple act of applying for an NPI number when you do not fit the legal definition of a qualified individual, I believe, constitutes wire fraud since the application is filed on line. I do not believe that the advice to apply is an acceptable answer to the problem at hand.

    A link to Ms McCardel’s presentation regarding atypical providers: http://www.ehcca.com/presentations/HIPAA12/danes.pd

    Ms McCardel and I have discussed the existence of a taxonomy code for veterinarians. It is important to recognize that the taxonomy codes were not created for purposes of the NPI number process.

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