Peyton , Patricia MD

(1) All health care providers applying for NPIs must indicate their type/specialization (Healthcare Provider Taxonomy Code) in their NPI application. However, neither NPPES nor the NPI Enumerator verify that the health care providers applying for NPIs are of the type/specialization they state on their NPI applications. While NPPES/NPI Enumerator validates the specialization against the current version of the Healthcare Provider Taxonomy Code set, NPPES/NPI enumerator does not verify that a particular health care provider is actually of that type/specialization. Therefore, for purposes of this NPRM, you may wish to find and use a verifiable source of the physicians' specialty. (2) All health care providers are eligible for NPIs. The Medicare program has required enrolling health care providers to have NPIs as a condition of enrollment since 2006. The Affordable Care Act requires all health care providers enrolling in Medicare or Medicaid/CHIP to have NPIs and to report their NPIs on their enrollment applications/provider agreements and their claims. (Most other health plans also require their health care providers to have NPIs.) So, contrary to what is stated in this NPRM, any physician affected by this NPRM (and thus enrolled in Medicare and/or Medicaid/CHIP) would be required by statute to have an NPI. (3) A physician's NPI never changes. It exists virtually until he/she requests that it be deactivated (e.g., upon retirement) or until it is deactivated by the NPI Enumerator upon his/her death. (4) Not all physicians (or other individuals, for that matter) have middle names (see required information on page 78754). (5) I think the NPRM needs to be clearer in the preamble of its definition of "physician." All professions that fall under the definition at 1861(r) are eligible for NPIs and, if enrolled in Medicare and/or Medicaid/CHIP, are required to have NPIs.