Behavioral-health PECOS taxonomy misalignment (highest-recoupment cohort)
Subset of H37 narrowed to NPIs with at least one behavioral-health NUCC code on their NPPES record. **Result: 44,875 of 147,693 comparable behavioral-health pairs (30.38%) show PECOS-NPPES mismatch — higher than the all-comers rate of 27.31% (H37).** Behavioral-health wrong-taxonomy is the highest-recoupment-risk category under the 2026 verification rules: payer rejection is automatic (not a warning), and the rejection covers the entire period the wrong code was in place. CA 5,524, NY 2,884, FL 2,403, TX 2,220 lead.
Headline
44,875 of 147,693 comparable behavioral-health NPIs (30.38%) show a PECOS PROVIDER_TYPE that does not resolve to any NUCC code on the NPI's NPPES record via the CMS Medicare↔NUCC crosswalk. Behavioral-health wrong-taxonomy is the highest-recoupment-risk category under the 2026 verification rules — payer rejection is automatic, not flag-and-investigate, and recoupment covers the entire window the wrong code was in place. This subset is the priority cohort for state PI offices and behavioral-health group practices to triage. Per-state CSVs at /api/v1/states/<state>/h38-behavioral-health-pecos-mismatch.csv.
44.9K / 147.7K = 30.38%
unit: count
What this means
Behavioral-health providers
Your taxonomy code drives every payer's service-coverage logic. A wrong code that has been in your PECOS record for years can trigger recoupment over that same multi-year window once a payer audit catches it. Run AINPI's lookup, check yours.
Behavioral-health group practices
Roster-wide PECOS audit before the 2026 enforcement window opens. The cost of fixing a CMS-855I refile is trivial; the cost of recoupment on a year of misclassified claims is not.
State Medicaid PI offices
The behavioral-health subset is the highest-priority slice within H37 for SMD-letter Element 4 (other comprehensive measures). The cohort is small enough per state to triage manually.
Null hypothesis
Behavioral-health NPIs do not exhibit a higher PECOS-NPPES taxonomy mismatch rate than the all-comers H37 baseline. The subset matches at the same ~27% rate.
Denominator
147,693 NPIs that are (a) Medicare-enrolled in PPEF, (b) have a PECOS PROVIDER_TYPE that maps through the CMS Medicare ↔ NUCC crosswalk, AND (c) carry at least one behavioral-health NUCC code on their NPPES record. Behavioral-health prefixes: 101Y (counselor), 103T (psychologist), 103G (clinical neuropsychologist), 103K (behavior analyst), 1041C / 1041S (clinical/school social worker), 106E (assistant behavior analyst), 106H (marriage & family therapist).
Data source
H37 input dataset filtered to NPPES behavioral-health NPIs. See `analysis/h38_behavioral_health_pecos.py`. Per-state CSV at `/api/v1/states/<state>/h38-behavioral-health-pecos-mismatch.csv`.
Notes
Behavioral health gets carved out from H37 because the regulatory consequences are harder. A mental-health counselor billing E/M codes their NPPES taxonomy doesn't cover, or a marriage-and-family therapist whose PECOS record was filed as a general counselor, will trigger automatic claim rejection. Then recoupment over the multi-year window the wrong code was in place. The cohort surfaced here is the highest-priority triage list for behavioral-health group practices doing pre-emptive PECOS-cleanup audits. State PI offices should treat this subset as priority within H37 for the SMD-letter Element 4 (other comprehensive measures) submission.