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National Provider Identifier Federal Requirement for Behavior Analysis Service Providers

Date: 03/31/22

Fort Lauderdale, Florida

Note: This is an update to a previous post.

The Centers for Medicare and Medicaid Services (CMS) recently notified the Agency for Health Care Administration (Agency) that Florida Medicaid behavior analysis providers are not exempt from the federal requirement to have a National Provider Identifier (NPI).

Effective immediately, behavior analysis providers are required to provide an NPI as a condition of enrollment with Florida Medicaid.

The NPI is a Health Insurance Portability and Accountability Act (HIPAA) Administrative Simplification Standard. The NPI is a unique identification number for covered health care providers. Covered health care providers and all health plans and health care clearinghouses must use the NPIs in the administrative and financial transactions adopted under HIPAA. You can find out more about the CMS requirement for an NPI.

In accordance with the federal requirement, all rendering, ordering, prescribing, or attending providers enrolled in Florida Medicaid must have an NPI on file with the Agency. This includes all behavior analysis providers, provider type 39, enrolled with Florida Medicaid, and all provider type 39 specialties, lead analysts (specialty type 392), assistant behavior analysts (specialty type 391), registered behavior technicians (specialty type 390), and behavior analysis groups (specialty type 393).

If an enrollment file does not include an NPI, behavior analysis providers must provide an NPI to the Medicaid fiscal agent as soon as possible, but no later than April 1, 2022.

Starting July 1, 2022, claims will deny if submitted without the rendering, billing, and referring providers’ NPIs.

  • Please note: Providers must have a unique address for their Taxonomy/specialty. If there are multiple BA providers in one building, each address must include a unique identifier, such as a room number. This is a federal requirement and extensions or exemptions will not be granted.

For additional information on NPI requirements, please refer to the NPI Quick Reference Guide (PDF).

Providers should complete the following steps to verify if an NPI is on their enrollment file:

  1. Log into their Florida Medicaid Secure Web Portal account.
  2. Select Demographic Maintenance.
  3. Review the Provider Information panel to confirm if an NPI is present.

Providers that do not have an NPI should complete the following steps in order to update their enrollment file with the Agency:

  1. Apply for and receive an NPI through the National Plan & Provider Enumeration System. 
  2. Download and review the Florida Medicaid NPI Registration Form Guide (PDF) for instructions on how to register their NPI with Florida Medicaid.
  3. Complete the NPI registration form, which can be accessed by navigating to the Florida Medicaid Public Web Portal, select Enrollment from the Providers Services Tab, then Enrollment Forms.

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