Multi-enrollment NPIs with conflicting state addresses
PPEF has ~2.98M rows but ~2.56M distinct NPIs — so ~400K NPIs have multiple enrollments. Many are legitimate telehealth or multi-state practice. **Result: 255,700 of 2,556,656 distinct NPIs (10.0%) have enrollment records in 2 or more distinct US states.** Top NPIs include telehealth companies enrolled in all 51 jurisdictions (VIRTA MEDICAL PC, ACCESS TELECARE PLLC). TX 36,364, FL 31,680, NY 30,320, DC 30,247 lead — DC is high because of national-scope organizations enrolling in DC for federal contracting. Under the 2026 verification rules, every multi-state enrollment is a flag requiring triage: telehealth (document) · stale (file CMS-855I to close) · fraudulent (refer).
Headline
255,700 of 2,556,656 individual NPIs in the CMS Public Provider Enrollment Extract (PPEF, PPEF 2026-04-01) have enrollment records in 2 or more distinct US states. Many are legitimate multi-state practitioners (telehealth, hospital + private, split-state practices); a subset are stale records from partnership moves or retirements that never refiled. Under CMS's 2026 verification rules (PECOS designated as authoritative for Medicare enrollment), every multi-state enrollment is a flag requiring state-Medicaid triage: telehealth (verify and document) · stale (file CMS-855I to close legacy enrollment) · fraudulent (refer to PI). Per-state CSVs at /api/v1/states/<state>/h39-pecos-multi-state.csv list each NPI in the state's cohort with the other states they're also enrolled in.
255.7K / 2.6M = 10.00%
unit: count
What this means
State Medicaid PI offices
The conflicting-state cohort is a triage layer: any NPI in your state with a competing out-of-state PECOS record is either telehealth (verify), stale (clean up), or fraudulent (refer). Per-state CSV gives your team the working list.
Individual providers
If you moved practice states and did not close the old enrollment, your PECOS has two competing records. The new authoritative-source rule means the wrong one might win during a verification check. File a CMS-855I to close the old enrollment.
Null hypothesis
Every NPI with multiple PPEF enrollment records has consistent state metadata across those records. Multi-state listings only occur with consistent metadata.
Denominator
2,556,656 distinct NPIs in PPEF (2026-04-01) across 2,981,800 enrollment records. Numerator = NPIs with ≥2 distinct US-jurisdiction STATE_CD values across their enrollment records. Per-state attribution: each state where the NPI has any enrollment record (so an NPI enrolled in VA + MD appears in both states' CSVs).
Data source
PPEF (`frontend/data/cms-claims/PPEF_Enrollment_Extract_2026.04.01.csv`). Single pass, GROUP BY NPI, COUNT(DISTINCT STATE_CD) > 1. Per-state CSV at `/api/v1/states/<state>/h39-pecos-multi-state.csv`. See `analysis/h39_pecos_multi_enrollment.py`.
Notes
Multi-state enrollment is not inherently a problem. The signal is ambiguous between legitimate multi-state practice (telehealth, hospital + private practice split) and stale records (partnership move, retirement, group-practice split where the legacy enrollment was never closed). Under the CMS 2026 verification rules, every multi-state enrollment is a flag — your PI team's job is to categorize: telehealth (document the practice arrangement) · stale (file CMS-855I to close the legacy record) · fraudulent (refer). The detail file at /api/v1/findings/pecos-multi-enrollment-state-mismatch-detail.csv lists all matches nationally; per-state CSVs at /api/v1/states/<state>/h39-pecos-multi-state.csv carry the rows your state owns triage on.