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One of the most common misconceptions I have frequently encountered with chiropractic practices involves whether a chiropractor who is new to the practice can be billed under another chiropractor’s National Provider Identifier (NPI) until the new chiropractor is credentialed with Medicare, Medicaid, and commercial payers. As a general rule, no, this is not appropriate. Claims should be billed under the NPI of the chiropractor who actually performed the service. Billing under another chiropractor’s NPI can create misrepresentation risk and possible False Claims Act exposure if the billing provider did not furnish the service.

What the Rule Means in Practice

For chiropractic practices, the safest baseline is simple: bill under the rendering chiropractor’s own NPI. That matters because payer credentialing, supervision, documentation, and coverage rules are tied to the individual provider who rendered care. Medicare chiropractic coverage is already a high-risk compliance area, with CMS reporting a significant improper payment rate driven largely by documentation problems. That makes accurate rendering-provider billing especially important for chiropractic claims. Even when a practice is organized as a group and payment is reassigned to the entity, the claim still needs to reflect the correct rendering provider information in accordance with payer rules.

Practices sometimes ask whether an associate chiropractor can simply bill under the owner’s NPI. The answer is usually no unless a specific exception is satisfied. Incident-to billing has strict conditions and does not apply in this scenario. Likewise, substitute billing rules such as locum tenens are temporary and highly technical; they are not a substitute for proper enrollment and credentialing of an associate. Because these rules are nuanced and payer-specific, chiropractic practices should verify whether a particular payer even permits the arrangement before claims are submitted.

Best Practices for Chiropractic Practices

Best practice is to align enrollment, credentialing, scheduling, documentation, and claim submission so the rendering chiropractor on the claim matches the clinician who actually treated the patient. Practices should maintain written billing protocols, train front-desk and billing staff on rendering-provider selection, confirm payer-specific supervision and substitute provider rules before use, and perform periodic chart-to-claim audits. If a chiropractor is newly hired or not yet credentialed with a payer, the practice should not assume billing under another chiropractor’s NPI is permissible; instead, it should confirm the payer’s written policy and delay or structure services accordingly until compliant billing is possible.

Top 5 Billing Compliance Tips

1. Bill under the rendering chiropractor’s NPI.
2. Do not use incident-to billing as a shortcut; confirm every supervision, established-patient, plan-of-care, and payer-specific requirement first.
3. Use locum tenens or reciprocal billing only when the arrangement is temporary, supported by documentation, billed with the correct modifier, and allowed by the payer.
4. Keep provider enrollment, credentialing, reassignment, and rendering-provider records current across government and commercial payers.
5. Audit documentation against claims regularly, especially for medical necessity, maintenance care exclusions, modifiers, and the identity of the provider who performed the service.

Bottom line: chiropractors should assume that services must be billed under the NPI of the chiropractor who performed them, unless an exception such as locum tenens applies and can be appropriately documented. For most chiropractic practices, the compliance-forward approach is to credential each provider correctly, match the claim to the actual rendering chiropractor, and validate any exception with the payer before billing.

To learn more about how our firm serves chiropractic practices, please contact BMD Member Jeana Singleton at jmsingleton@bmdllc.com or 330-253-2001.