The payer's system has an edit in place requiring an NPI in the 2310C loop. Can you please clarify if a payer can require a provider to send the same NPI in the 2310C loop as the 2010AA loop?
The Service Facility Location Name is “Required when the location of health care service is different than that carried in Loop ID-2010AA (Billing Provider). If not required by this implementation guide, do not send."
The NM108 and NM109 of this segment which carries the NPI is "Required when the service location to be identified has an NPI and is not a component or subpart of the Billing Provider entity. If not required by this implementation guide, do not send." If the service location identified does not have an NPI and/or is a component or subpart of the Billing Provider, then the NPI must not be sent. A receiver (in this case a payer) cannot require the sender to send situational data. Situational data must only be sent when the situational rule is met.
The first TR3 note of the 2310C NM1 segment reads "When an organization health care provider’s NPI is provided to identify the Service Location, the organization health care provider must be external to the entity identified as the Billing Provider (for example, reference lab). It is not permissible to report an organization health care provider NPI as the Service Location if the entity being identified is a component (for example, subpart) of the Billing Provider. In that case, the subpart must be the Billing Provider." This effectively disallows sending the same NPI in the 2310C loop as was reported in the 2010AA loop.