State Advocacy Issue

 National Provider Identifier Numbers and Veterinarians

June 2008

The National Provider Identifier (NPI) is a Health Insurance Portability and Accountability Act (HIPAA) standard adopted to track health care providers' prescriptions. The NPI is a unique, 10-digit identification number for covered health care providers, adopted to monitor Medicare and Medicaid fraud, and used in administrative and financial transactions listed under the federal HIPAA law. When HIPAA was established, the American Veterinary Medical Association asked the U.S. Department of Health and Human Services if veterinarians were covered under the Act, and were told they were not. Consequently, veterinarians have not generally obtained NPIs.

Recently, we received reports from various states that pharmacies have begun asking prescribing veterinarians to supply NPI numbers along with DEA numbers before filling prescriptions. One of the pharmacies, Shopko, reportedly agreed to send a notice to all its pharmacists explaining how to manually override the system for veterinary prescriptions. However, we have heard that Walgreens and Wal-Mart also have requested NPI numbers from veterinarians.

Meanwhile, a new law in New Jersey will require, as of Oct. 1, 2008, all prescription blanks to be serially numbered and pre-printed with the prescriber's NPI number. The purpose is to address prescription fraud from clients making copies of prescriptions. Veterinarians can obtain NPI numbers free from the federal government via the internet, or calling an 800 number. For more information about the National Provider Identifier Number, see https://nppes.cms.hhs.gov, or contact The Centers for Medicare & Medicaid Services with specific inquiries or questions at 1-800-465-3203.

The NJVMA is working to obtain a veterinarian exemption and has asked the state's attorney general' office for an opinion on whether veterinarians need to obtain NPIs. The concern is that such a requirement will blur the line between veterinarians and physicians and cause veterinarians to be accountable under privacy laws which currently apply only to doctors practicing human medicine.

The other problem with the NPI system is that there is no category for veterinarians, such as physician, dentist, hospital, etc, as veterinarians were never intended to be covered under the legislation. Pharmacy chains will likely be using software with a screen that requires the entering of an NPI number. If a veterinarian doesn't have one, the transaction will likely fail.

Rather than issuing NPI numbers to veterinarians, we recommend that veterinarians ask pharmacies implementing the NPI system to use software that allows a prescriber to bypass the NPI for veterinary prescriptions, or alternatively, issue a generic NPI number for veterinarians in order to get past that screen.

Source:   Staff research, AVMA State Legislative and Regulatory Affairs Department
Contact:  Tara Southwell, State Policy Analyst, AVMA State Legislative and Regulatory Affairs Department, 847-285-6779.