CMS thanks the ASC X12 for working with us to identify both the locum tenens and absent provider on a claim. The workaround included identifying the locum tenens provider in the Rendering Provider Loop, which requires an NPI to identify the provider if the provider is eligible to receive one. The CMS Office of General Counsel has indicated that CMS cannot require providers not enrolled in Medicare to obtain NPIs, and there may be locum tenens providers not otherwise required to obtain an NPI (e.g., submit own claims only on paper). Because locum tenens providers need not be enrolled in Medicare and because they may not necessarily have an NPI, there will be situations where the locum tenens provider cannot be identified in the Rendering Provider Loop.

CMS requests an amendment to permit identifying the locum tenens provider with a universal identifier (e.g., social security and/or state medical license) or a new workaround that will allow identifying the locum tenens provider without an NPI.