Atypical Provider: Enrolling in Medicaid Without an NPI

Most Medicaid providers bill with an NPI, the 10-digit National Provider Identifier. Some NEMT companies never get one, because their state enrolls them as atypical providers and gives them a state number to bill with instead. Which group you fall in decides what goes on every claim you send.

What makes a provider atypical

HIPAA defines health care as care, services, or supplies related to a person’s health, such as diagnostic, therapeutic, or rehabilitative care (45 CFR 160.103). The NPI is for the people and organizations that furnish it. When HHS created the NPI in its final rule of January 23, 2004, it named taxi service among the “atypical or nontraditional services” that are only indirectly health care related. An organization that furnishes no health care is not eligible for an NPI, the rule says, and a health plan cannot require it to get one, even if the plan makes it send standard electronic claims.

CMS’s Medicaid Provider Enrollment Compendium, last updated November 17, 2025, tells states how to apply this:

• Eligibility turns on whether you furnish health care, not on what your provider type is called.
• States must require NPIs from providers that qualify and may assign a state Medicaid ID to those that do not.
• If a provider that does not qualify gets an NPI anyway, the state should use another identifier, such as its own Medicaid ID.
• NEMT providers that meet the federal definition of a health care provider may apply for an NPI.

Federal rule 42 CFR 431.107 asks each Medicaid provider for its NPI “if eligible.” So your state Medicaid agency makes the call for your company type.

Which states treat NEMT companies as atypical

Several states enroll van and sedan companies without an NPI, and Texas mostly does not. Here is how five states handle it, as of October 2026:

State	Can a NEMT company enroll without an NPI?	What you bill with
North Carolina	Yes, as an atypical organization	Provider number from NCTracks
Indiana	Yes, for transportation other than ambulance	IHCP Provider ID
Michigan	Yes, NEMT enrolls in CHAMPS as atypical	Form MSA-4674 for fee-for-service trips
Illinois	Yes, as an atypical agency	HFS provider number
Texas	Generally no, an NPI comes first	NPI. Mileage-paid drivers use an API

• North Carolina. NC Medicaid says atypical providers do not provide health care services, will not be issued NPIs, and file claims with provider numbers from NCTracks. It names non-emergency transportation providers as the example. See the North Carolina guide.
• Indiana. The Provider Enrollment module (version 7.1, September 8, 2026) says transportation providers other than ambulances and air ambulances are not considered health care providers. They are not required to have NPIs and use the IHCP Provider ID every enrolled provider receives. See the Indiana guide.
• Michigan. The Medicaid Provider Manual dated October 1, 2026, in its MI Coordinated Health chapter, calls atypical providers organizations that do not provide health care, names NEMT, and says they may not have an NPI. For fee-for-service rides you must be enrolled in CHAMPS on the date of service, and you send form MSA-4674, the Medical Transportation Statement, with receipts to the authorizing party within 12 months of the ride. MDHHS lists an atypical provider line, 800-979-4662, for questions on authorizations and payment. See the Michigan guide.
• Illinois. HFS’s IMPACT enrollment manual for transportation providers says, as of October 2026, that companies driving medicars, service cars, taxicabs or livery cars, or private autos can enroll as an Atypical Agency, provider type Transportation-AA. The transportation handbook (March 11, 2024) has providers bill with their NPI, or with their provider number if atypical. See the Illinois guide.
• Texas. The October 2026 provider manual says an NPI must be obtained before a provider enrolls, and the enrollment system lists the types that may enroll without one. The atypical provider identifier (API) goes by letter from TMHP to individual transportation participants, people paid mileage to drive themselves, a friend, or a family member. The transportation handbook has rideshare companies bill with one too. See Texas NEMT provider enrollment.

How an atypical company fills out the claim

On the paper CMS-1500, box 33a holds the billing NPI. Box 33b holds a qualifier followed by another ID, with no space between them, and the NUCC instructions (version 13.0, July 2025) list G2, Provider Commercial Number, as the qualifier for an ID a payer assigns.

Indiana shows how it works. Its Claim Submission and Processing module (version 8.5, February 24, 2026) sets these fields for a company billing as atypical:

CMS-1500 field	Provider with an NPI	Atypical NEMT company
33a, billing NPI	The billing NPI	Leave blank
33b, other ID	ZZ or PXC and a taxonomy code, if needed for a match	G2 and the IHCP Provider ID
24I, shaded	ZZ or PXC for a taxonomy code	G2
24J, shaded	Taxonomy code, optional	The IHCP Provider ID

An IHCP Provider ID is nine digits and a letter for the service location. With a made-up ID, box 33b reads G2100012345A. On the electronic 837P, the same ID goes in loop 2010BB, segment REF, with G2 in REF01 and the ID in REF02 (companion guide 4.2, November 2024).

Three warnings from Indiana. It destroys paper claims it can neither process nor send back: those that arrive without the NPI or the atypical provider’s IHCP Provider ID, the provider name, and a return address. Since January 29, 2026, it charges $5 for each new fee-for-service paper claim, takes the fee out of later payments, and points providers to its online portal or the 837P instead (bulletin BT2025181). And most fee-for-service NEMT trips there are brokered by Verida, so you bill Verida for those, not the IHCP (transportation module, August 19, 2025).

Texas uses box 33A differently. The October 2026 Medical Transportation Program handbook has demand response companies enter their NPI or API, individual transportation participants and rideshare companies enter their API, and every provider put its taxonomy code in box 33B. The rest of the form is in CMS-1500 for NEMT.

Atypical still means enrolled and screened

Atypical changes your identifier, not your obligations. North Carolina’s provider permission matrix (August 16, 2026) treats NEMT van companies (taxonomy 343900000X) the same either way: moderate risk, a site visit, the federal application fee, and the NEMT Driver Attestation form signed by your office administrator. In Michigan, the October 1, 2026 manual bars the dual eligible plans in MI Coordinated Health from paying NEMT providers that are not enrolled in CHAMPS.

Before you apply, ask your state’s provider enrollment office which enrollment type fits a ride company. If it wants an NPI, start with how to get an NPI number for NEMT and choose the right taxonomy code. If it enrolls you as atypical, the number it assigns is your Medicaid provider number, and that is the one your claims carry.