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Medical Provider Newsletter

April 2022

May a provider bill under another provider's NPI and related Q&A

May a medical provider bill EMI Health under another provider's name and NPI?

In general, EMI Health requires medical providers to submit claims under their own names and NPIs. There are limited exceptions.

What if the rendering provider is employed by another provider?

If a provider works for a medical group or an incorporated individual, that organization's name and Type 2 NPI is submitted as the billing provider. However, the provider performing the services must report their name and NPI as the rendering provider. Just because one provider works for another does not mean the employing provider may submit claims on behalf of the employee--even temporarily while a new employee waits for credentialing with EMI Health to be completed.

What if one provider is supervised by another provider?

EMI Health encourages advanced practice providers (physician assistants and APRNs) to contract with, and submit claims directly to, EMI Health. However, supervising physicians may submit claims on behalf of the advanced practice providers which they supervise. One midlevel provider may not bill for another midlevel provider.

Supervising mental health providers may submit claims for new mental health providers who are working on obtaining the hours required to be a fully-licensed independent practitioner, in accordance with the guidelines of the Utah Administrative Code. Qualified mental health provider supervisors that meet the requirements outlined by the Utah Office of Administrative Rules may submit eligible claims rendered by an associate under their supervision. State guidelines for supervising requirements can be found at utah.gov. 

All other medical providers must bill EMI health directly for services they render, regardless of whether they are contracted with EMI Health or supervised by another provider.

NPI basics

Type 1: Individual providers are each required to obtain a Type 1 (individual) NPI. An individual is eligible for only one Type 1 NPI, and Type 1 NPIs may not be shared among providers in an organization.

Type 2: Providers who are organizations, including healthcare groups and individuals who have incorporated their practices, must also obtain a Type 2 (organizational) NPI. Large organizations may have subparts that need to be uniquely identified with their own Type 2 NPIs.

Billing: When submitting claims, the individual Type 1 NPI is used to identify the provider who performed the service, while the organizational Type 2 NPI identifies the entity to be paid. Individual unincorporated providers may use the Type 1 NPI for billing and rendering.