All school-based audiologists and speech-language pathologists (SLPs) who file Medicaid claims will be required to obtain a National Provider Identifier (NPI) number in 2014. Learn what you need to know about NPI and Medicaid—get the facts below.
The National Provider Identifier (NPI) number is a Health Insurance Portability and Accountability Act (HIPAA) Administrative Simplification Standard. The NPI number is a unique identification number for covered health care providers. Covered health care providers and all health plans and health care clearinghouses must use the individual provider's NPI number in administrative and financial transactions adopted under HIPAA. The NPI number is a 10-digit number that is used as a provider's identifier. The NPI number must be used in place of older legacy provider identifiers that may have been previously assigned. NPI numbers will/may be a required part of the documentation needed to complete a Medicaid claim, depending on the applicable state Medicaid plan. Additional information is posted on the Centers for Medicare & Medicaid Services (CMS) website.
It is important for you, as a school-based clinician, to know and understand what is being required in your state. While some states may require school-based providers to obtain and use their individual NPI numbers when billing for services rendered, other states allow school-based providers to bill under the facility (e.g., school district or facility) identifier. School-based professionals should consult with state and local administration to determine if an individual NPI number is required. The decision of whether you must have an NPI number or "unique identifier number" will be made by your individual state's health care authority.
NPI Numbers Required for Audiologists and Speech-Language Pathologists
If a state requires NPI numbers for school-based Medicaid billing, the district may require each school-based audiologist and SLP to get an NPI number. Whether or not you are required to get an NPI may depend on your contract with the district or the general teaching contract negotiated by the union. It could be considered insubordination—in some settings—to refuse, but that may be open to interpretation. You may have an appeal process if this becomes an issue for you.
Audiology and Speech-Language Pathology Assistants
Whether or not assistants will need to get NPI numbers depends on their respective Medicaid state plan amendments. Assistants should refer to the states' plans for additional information.
The actual implementation of CMS Rule 6028 will likely vary by state and school district. Some states are reported to be requiring implementation by 2014.
There is no charge to get an NPI. Audiologists and SLPs can apply online or by calling 800-465-3203 to request a paper application. It takes less than 5 minutes to apply online, and the number is issued within a few minutes. For further information about obtaining an NPI, please visit the NPI Page on the CMS website.
Some school districts will collect information and submit the application for the NPI with their organizational applications. Check with your district regarding the process for obtaining your individual NPI.
Note: The provider type is 23 (speech, language, hearing service provider). The taxonomy number for audiologist is 231H00000X. The taxonomy number for SLP is 235Z00000X.
ASHA does not believe that audiologists and SLPs will need to change their billing procedures. This regulation only requires the NPI number or "unique identification number" for identification of the provider who bills the service.
Although the majority of Medicaid claims are for services provided by SLPs, in most areas, the Local Education Agency (LEA) that bills Medicaid directly for the services provided, receives the funds. Medicaid reimbursement rarely comes back to the individual SLP providing the services. Although the NPI of the provider may be listed on the claim as the "rendering" provider, payment is issued to the LEA.
Depending on how you are employed by a school district, your taxes may or may not be affected. Typically, the health care agency contracts with the school district, and, although the NPI of the provider may be listed on the claim as the "rendering provider," the personal taxes of the clinician would not be affected. If, however, the clinical is an independent contractor billing Medicaid directly for services provided in the school, reimbursement received would be taxable income. If you are unsure if/how your tax status might be affected, consult an attorney.
This page was developed by the 2013 School Finance Committee and endorsed by ASHA's Medicaid Committee.