A physician who pulls a remittance summary, receives a records request, or takes a call from an investigator sometimes finds claims billed under their own National Provider Identifier (NPI) for encounters they did not furnish or cannot place. A telehealth company the physician contracted with filed those claims, using billing rights the physician signed away at onboarding. The physician's name and NPI are on every one of them, and Medicare treats the physician, not the platform, as accountable for them.
How a Telehealth Company Gains Access to Your NPI
The NPI is a permanent identifier tied to the individual provider, not to any single employer or platform. Once the National Plan and Provider Enumeration System assigns an NPI to a physician, that number follows the physician across every practice setting under 45 C.F.R. § 162.406 and § 162.410. A telehealth company cannot bill Medicare on its own identity for a contracted physician's professional services. Most onboarding packets instead include reassignment of benefits paperwork, the enrollment document authorizing the company to submit claims and collect payment on the physician's behalf, often bundled with other onboarding forms rather than presented as its own decision.
What the Reassignment Does Not Transfer
Reassignment transfers the right to bill and collect payment. It does not transfer the physician's own enrollment, and it does not transfer responsibility for the accuracy of what gets billed. Under 42 C.F.R. § 424.516, every enrolled provider certifies the accuracy of the information tied to their enrollment for as long as it stays active. HHS-OIG has warned physicians directly on this point: one who reassigns billing rights "may be liable for false claims submitted by entities to which they reassigned their Medicare benefits" and should apply heightened scrutiny before signing reassignment paperwork over to a company. A compensation model that pays a physician per encounter regardless of whether the physician reviewed or directed the billed care can also raise anti-kickback statute questions separate from the accuracy problem, and claims billed as incident to the physician still have to satisfy the supervision conditions in 42 C.F.R. § 410.26.
Obtaining Your Own Claims History and Withdrawing the Reassignment
A physician who suspects unfamiliar billing does not have to wait for a records request. Each Medicare Administrative Contractor maintains a provider portal and an interactive voice response line that return claim status and payment history once the physician's Provider Transaction Access Number is entered. Reviewing that history against the physician's own calendar and clinical records is how a gap between what was billed and what was furnished gets identified. A reassignment can be withdrawn at any point through Medicare's enrollment system, by either the physician or the entity. Withdrawal cuts off the company's ability to bill future claims under the physician's number; whether the claims already filed were accurate, and whether any must be repaid, is a separate question it does not answer.
Why Silence After Discovery Is Itself a Problem
Finding a claim the physician did not furnish or cannot verify is the first step, and what the physician does next carries its own consequences. A physician who confirms the pattern against their own claims history and then does nothing moves from an unknowing billing error toward a separate question of what the physician knew and when, on top of the underlying recoupment exposure. The False Claims Act reaches claims submitted with actual knowledge of falsity, but also claims submitted in deliberate ignorance or reckless disregard of the truth, a standard that does not require the physician to have billed anything personally. It is the physician's own exposure, not the platform's, that a UPIC or MAC review will be evaluating, against the broader enforcement pattern documented in HLA's reporting on telehealth fraud enforcement and telehealth billing inside Medicare Advantage plans.
Every claim filed under a physician's NPI creates exposure that belongs to the physician, not the platform that billed it.
Why Early Legal Counsel Is Critical
It is critical that physicians promptly retain experienced healthcare defense counsel upon discovering claims billed under their NPI that they did not furnish or cannot verify. Early legal intervention can protect the physician's rights, guide a proper review of the claims history without creating unnecessary admissions, evaluate whether the reassignment should be withdrawn, and allow counsel to communicate with the contractor or the telehealth company on the physician's behalf. Delaying legal representation can significantly affect the outcome of a matter and expose the physician to unnecessary risk.
How Health Law Alliance Can Help
Health Law Alliance has handled 5,000+ matters across healthcare regulatory and audit defense over 25+ years, including matters where a physician's NPI was used by a contracted business to bill claims the physician had not furnished. If you have found claims billed under your NPI that you do not recognize, contact Health Law Alliance's telehealth law and telemedicine attorneys for a free, confidential consultation.
