Section title: Requests for Interpretation
270 has NPI (2100B NM109) and 2100B REF

Does the 005010X279 implementation guide for the 270/271 standard not permit a 270 request transaction to contain a 2100B REF Information Receiver Additional Identification segment when an NPI is reported in 2100B NM109 (2100B NM108='XX')?


We recently had another covered entity indicate as a receiver of the 270 transaction, that we should be rejecting a 270 transaction that contains a valid health care provider's NPI (2100B NM108='XX') and a 2100B REF segment because only the NPI is mandated. We do not reject the 270 in this scenario because the 2100B REF segment situational rule states, "If not required by this Implementation guide, may be provided at sender’s discretion, but cannot be required by the receiver." As the receiver, our business process is to ignore the 2100B REF segment and process it using the NPI. We are requesting clarification to confirm we are adhering with implementation guide requirements.

RFI Response

The situational rule for the Information Receiver Additional Identification explicitly states “Required when the information in 2100B NM1 is not sufficient to identify the information receiver.  If not required by this implementation guide, may be provided at the sender's discretion, but cannot be required by the receiver.” Regardless of if the NM108/109 contains an NPI or TIN, the REF01/02 may contain any ID the information sender feels would be beneficial to the information receiver. The usage of the REF segment situational rule, before, during, or after the NPI Adoption Date, is the same.