"business name" and reporting clarification needed for providers with SSN only. #890
Description
Elaborating on https://github.com/CMSgov/price-transparency-guide/tree/master/schemas/in-network-rates#additional-notes
"In contractual arrangements that are only made at the TIN level, where NPIs are unknown or otherwise unavailable, the value "0" should be reported for the NPI field. In contractual arrangements where both the NPI and TIN are available, both are required to be disclosed."
The "NPI Field" is in the "Providers Object". There is not clarification regarding the "Tax Identifier Object"'s "value" when type is "npi", in situations where the provider has neither EIN nor NPI? When the NPI array is [0] I propose we allow "Tax Identifier Object" type "ein" value "0", and disallow "Tax Identifier Object" type "npi" value "0". Why? Because "ein" comes with a requirement to report "business name", and the assumption that we can look up business name from NPI does not hold true when NPI zero is used.