1531 stated that if either name of NPI were different, then 2310B was required. We have run into a situation where the provider sent the name associated with the NPI (from NPPES) in the 2010AA loop. In 2310B, the provider sent the name that appears in the NPPES other name column. This provider is a lab. In this situation, is this compliant?
The Situational rule, "Required when the Rendering Provider Information is different than that carried in Loop ID-2010AA Billing Provider. If not required by this implementation guide, do not send." does not require that the Billing and Rendering Providers be different entities. It only requires that the Rendering Provider information be different than what was carried in Loop ID-2010AA Billing Provider. Therefore, the situation you describe in your request for interpretation is compliant with the 005010X221A1 005010X222A1 TR3.
NPI compliance or NPPES related questions are outside the purview of ASC X12. Please direct those questions to the Centers for Medicare and Medicaid Services (CMS).