Applying for a National Provider Identifier: Information and guidance for psychologists

A how-to guide for licensed APA members applying for identifying codes required under HIPAA

by Legal/Regulatory Affairs and Communications Staff

June 21, 2006 — This article is intended to assist licensed APA members in applying for a National Provider Identifier (NPI), including choosing a provider “taxonomy code,” as required by the Health Insurance Portability and Accountability Act (HIPAA).

The information and guidance in this article addresses the following questions:

  • What is the NPI and who needs to apply for it?

  • What is involved in the application process?

  • What are the NPI “taxonomy codes”?

  • What guidance does the APA Practice Organization offer about selecting a taxonomy code or codes?

  • How long do I have to revise my NPI application if necessary?

About the NPI
The NPI is a unique 10-digit number assigned to every health care provider or entity that applies for it. This number will replace other numbers that have been assigned to health care professionals by government and private insurers for use in billing.

As of May 23, 2007, all health care professionals will be required to use their NPI when billing electronically any government or private health insurer. Once a health professional receives an NPI, that number will be assigned to that health professional for his or her entire career, regardless of whether the health professional relocates, changes employers or even changes health professions.

Unlike identifiers used by the government and insurers in the past, the NPI is a random number. It does not reveal any information about the health professional, such as geographic location or type of practice.

Who must apply for an NPI
All “covered entities” under HIPAA, which includes all health care professionals who are required to comply with this federal law, must obtain an NPI no later than the May 23, 2007 deadline. (See the HIPAA section for additional information about what constitutes a “covered entity” under HIPAA.)

In addition, any private health insurer can require that health professionals who bill the insurer use an NPI, even if the billing is done by mail rather than electronically. This means that even psychologists who are not considered “covered entities” under HIPAA may be required to get an NPI. For this reason, the APA Practice Organization encourages all psychologists who bill insurers, including federal and state programs, to obtain an NPI.

Practitioners should also be aware that sole proprietorships are considered to be individuals for purposes of obtaining an NPI. For that reason, sole proprietorships should apply as individuals, using a social security number, not their employer identification number (EIN).

Steps in the NPI application process
Electronic application process
Psychologists may complete and submit the NPI application form online by accessing the NPPES website. You will be able to complete the application quickly, so long as you have all the required information ready before you begin. The list of information needed for individuals applying for an NPI includes:

  • Health practitioner name

  • Health practitioner date of birth

  • Country of Birth

  • State of Birth (if birth was in the United States)

  • Health practitioner gender

  • Social Security Number of other proof of identity

  • Mailing address • Practice location and phone number

  • Taxonomy (see “Obtaining the Correct Taxonomy Code” below)

  • State license information (required for certain taxonomies only)

  • Contact person name • Contact person phone number and e-mail

The website listed above will walk you through the steps involved in completing the application. The Center for Medicare and Medicaid Services (CMS) advises that electronic submission is the fastest way to obtain your NPI.

Paper application process
For any health care professional who wishes to complete a hard copy version of the application form and send it via regular mail, the application can be downloaded from the HHS website.

When you access the site, click on “CMS Forms.” Doing so will take you to a list of forms that includes the NPI application — CMS Form #10114.

The application form is three pages long, followed by instructions for completing the form. Individuals who render health care services are asked to complete Sections 2A, 3, 4A and 5.

Application form submitted by an employer
In some cases, a psychologist who is employed by a health care entity may find that the entity is willing to submit the NPI application on his or her behalf. For example, a hospital may do so for its employed providers. However, the health care entity is required to obtain your permission before filing an NPI application for you. If applicable, you could check with your billing or human resources department to find out whether your organization is planning to submit NPI applications for its employees.

Selecting a taxonomy code
As part of the application process, the Centers for Medicare and Medicaid Services (CMS) requires that all types of health professionals list a “taxonomy code” or codes.

A taxonomy code is a 10-digit alphanumeric identifier used to describe your health care practice and the professional services you provide. CMS representatives have indicated that the taxonomy code helps distinguish among health professionals — for example, where multiple providers have the same name.

The electronic version of the application lists the available taxonomy codes. First, you will be asked to choose among general categories of health care professionals. The applicable category for psychologists is “Behavioral Health and Social Service Providers.” Then you will be asked to choose among more specific categories. Two of the categories are “Psychologist” and “Neuropsychologist.” The remaining categories include 19 specialties listed under “Psychologist.”

The paper version of the application form does not list the taxonomy codes. To obtain the list of available codes, the application instructs you to go to the Washington Publishing Company website.

At the main page for this website address, you need to click on “Individual or Groups,” then click on “Behavioral Health and Social Service Providers.” That will take you to two codes applying to psychology — “psychologist” and “neuropsychologist.” If you click on the term “psychologist,” you will see the list of specialty codes that have been assigned to psychology.

Guidance from the APA Practice Organization
When considering which and how many taxonomy codes to choose, the APA Practice Organization generally encourages the simplest approach, which is for psychologists to pick just one code — the “psychologist” code (103T00000X) — rather than the specialty codes.

One exception to our general guidance about choosing only the “psychologist” code applies to qualified neuropsychologists.

Qualified neuropsychologists are encouraged to consider choosing two codes — the “neuropsychologist” code (103G000000X) as well as the “psychologist” code (103T00000X) — if providing services such as psychotherapy, feedback, and/or cognitive rehabilitation in addition to neuropsychological services makes up a substantial portion of their practice. (The definition of “neuropsychologist” as provided by NUCC in the taxonomy code list is: an individual with a doctorate degree, licensure in clinical psychology and specialized training or board certification in neuropsychology who practices or adheres to the principles of neuropsychology; a specialty within the field of psychology focusing primarily on neurobehavioral functioning.)

On the other hand, those qualified practitioners who provide only neuropsychological services may wish to consider simply choosing the neuropsychologist code (103G000000X).

The rationale for this guidance and additional information appears in the companion article, "The NPI Taxonomy Codes for Psychology: APA Practice Organization Offers Guidance, Advocates for Change."

If you choose a specialty code
If, after reviewing the information in the companion article, you would like to choose a specialty code, you should be aware of related information we received from CMS. Specialty codes are intended to reflect how you spend a substantial portion of your professional time. The codes are not intended to capture every type of service that you may offer or with which you have experience.

Therefore, if you elect to use a specialty code, you should choose the code(s) that most closely describe(s) your practice, but not necessarily all the codes that apply. The electronic application will allow psychologists to list up to 15 specialties, though we have been advised by CMS that they would consider choosing that many codes to be highly unusual.

The paper application provides room to list up to three specialties. Psychologists who wish to list more than three specialties may submit them on a separate sheet of paper. Please note that the instructions on the paper application do not state that psychologists may list additional taxonomy codes on a separate sheet of paper; however, we have been assured by CMS that this is permissible.

If your information changes
If the information you included on your NPI application changes, you are required to submit revisions to your application. This may be done electronically or using the same paper form discussed above. You have 30 days from the date of the change to submit the new information.