In the 837 P and 837I, our compliance vendor requires that either of these elements have to be present in order to pass compliance. However,the TR3 states that "Required on or after the mandated NPI Implementation Date when NM109
in Loop 2010AA is not used and an identification number other than the
NPI is necessary for the receiver to identify the provider." This situation applies to other provider loops in the transactions too.
Is this a valid interpretation of the TR3? Are either of these elements needed for a compliant transaction?
The 2010AA NM109 is required when a provider is eligible to receive an NPI, or the provider has received an NPI. The 2010BB REF is required when the NM109 in loop 2010AA is not used AND an identification number other than the NPI is necessary for the receiver to identify the provider. In a scenario where the provider was not eligible for, and did not have an NPI, and an identification number other than the NPI is not necessary for the receiver to identify the provider it would be consistent with the TR3 to send neither 2010AA NM109 nor the 2010 BB REF segment.
This interpretation also applies to the 5010 Dental 837 TR3.