We have a 278 Response scenario where the REF02 contains an employer identification number in the 2010B and 2010EA loops as well as an NPI in the NM109 of the same loops.
Both REF segment situational rules indicate the segment is required when used by the UMO to identify the requester or Patient Event Provider, and if not required, do not send. In addition, front matter section 1.10.1 says that the implementation guide accommodates both the NPI (to identify health care providers) and proprietary identifiers (to identify atypical/nonhealth care providers).
It seems reasonable that a 278 response would not include supplemental ID numbers if the provider has already been identified with an NPI that was provided in the 278 request.
Since the provider has already been identified with an NPI in the above scenario, is it compliant with the guide to also send the employer identification number in the 2010B and/or 2010EA REF segments of a 278 response although it is not considered a financial transaction?
It is compliant for the response to contain a REF02 value in addition to the NPI in the NM109 if the UMO used that information in determining the provider to complete the request, based on the situational rules in the 5010 TR3. We will review and correct on a future TR3 update to include that information would be returned only if submitted on the request and the entity is a non health care provider.