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Comments on HCFA-00047-P National Standard Employer Identifier

Contents

Introduction

Comments provided to the AAFP on National Standard Employer Identifier. Original 7/8/98. Revised: 01 Feb 2002.

Topics and Comments

Section I and II

This is certainly the least controversial of the Administrative Simplification Guidelines. The privacy concerns that are so important with the Social Security Number do not seem to apply to the IRS's Employer Identification Number. We should be careful, however, that we do not create a precendent that would be extended to use of the Social Security Number. Otherwise we will have little to add here that I can imagine!

Section III

Are there any physicians in private practice who would not have a EIN and would need to acquire one? The number would have to be very small, since anyone with partners or employees needs an EIN. In any case, it is not hard to aquire an EIN.

Obviously organizations that have multiple EINs should establish a "preferred" one for use in this context. I'd leave that up to the organization if possible.

Section V: Impact Analysis

No additional comment here. The costs do not seem excessive, considering the benefits.