New Federal Guidance Clarifies Use of NPI Numbers

By: Dr. Ashley Morgan, assistant director, Governmental Relations Division

The Department of Health and Human Services (HHS) has released new guidance for veterinarians stating that they are not eligible for National Provider Identifier (NPI) numbers.

In 2007, HHS mandated that all health care providers who bill for Medicare services should use NPI numbers in the administrative and financial transactions adopted under the Health Insurance Portability and Accountability Act (HIPAA). Veterinarians were included as part of this group on the NPI application forms, and individual pharmacies began requesting these identifier numbers from veterinarians when they filled prescriptions for veterinary patients.

In late summer, HHS issued new guidance for veterinarians, specifically stating that “NPI numbers are not eligible for veterinarians because they do not meet the regulatory definition of ‘health care provider’ as defined at 45 CFR 160.103.” HHS said that all veterinarians who previously procured NPI numbers should deactivate them.

While there are “Other Entity Identifier” numbers available to certain practitioners, AVMA is seeking clarification on whether veterinarians are eligible for any national identifier numbers. At the same time, veterinarians should not be barred from ordering a prescription at a pharmacy simply because they do not have an NPI number.

Veterinarians are encouraged to refer to their state rules on prescribing medications and review the Drug Enforcement Administration’s practitioner’s manual section on the inappropriate use of DEA registration numbers for more information. The DEA’s manual indicates that DEA registration numbers should not be used for identification purposes, a concept that AVMA supports in its policy, “Inappropriate Requests for DEA Registration Numbers.”

For more information, see AVMA’s blog post and the Centers for Medicare and Medicaid Service’s frequently asked questions.

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