Ordering, Referring, Prescribing, Attending, Supervising, and Operating (ORPASO) Providers

Section 6401(b) of the Affordable Care Act (ACA) includes requirements related to Ordering, Referring, and Prescribing providers.

Background

If MassHealth requires a service to be ordered, referred, or prescribed, then ACA Section 6401(b) requires the following.

• The billing provider must include an authorized ordering, referring, or prescribing provider’s National Provider Identifier (NPI) on the claim. 
• The ordering, referring, or prescribing provider must be enrolled with MassHealth as a 
  • Fee-for-Service (FFS) provider;
  • Ordering, Referring, or Prescribing only provider; or
  • Managed Care Entity (MCE) only provider.

The two latter groups do not submit claims or receive payment from MassHealth.

Note that there are other circumstances in which a provider’s NPI may also be required on claims to comply with Health Insurance Portability and Accountability Act (HIPAA) version 5010 billing requirements.

MassHealth will deny claims for certain health care services requiring an order, referral, or prescription from a physician or other health care professional unless an authorized ordering, prescribing, or referring provider’s NPI is included on the claim and that provider is actively enrolled with MassHealth. The following sections include more information on the affected claims.

MassHealth Services that Require an Order, Referral, or Prescription

For a billing provider to receive MassHealth payment, the following services and supplies require an order, referral, or prescription from a provider.

• Any service that requires a Primary Care Clinician (PCC) or Primary Care ACO (PCACO) referral (see 130 CMR 450.118(J) and 130 CMR 450.119(I))
• Adult Day Health
• Adult Foster Care
• Continuous Skilled Nursing
• Durable Medical Equipment (DME)
• Eyeglasses
• Group Adult Foster Care
• Home Health
• Independent Nurse
• Labs and Diagnostic Tests
• Medications
• Orthotics
• Oxygen/Respiratory Equipment
• Prosthetics
• Psychological Testing
• Therapy, including physical therapy (PT), occupational therapy (OT), and speech therapy (ST)

Provider Types Authorized to Order, Refer, or Prescribe

The following are the only provider types that may be listed on a claim as the ordering, referring, or prescribing provider. Interns, residents, and other trainees in the provider types who are authorized to order, refer, or prescribe services are also considered ordering, referring, and prescribing providers.

Massachusetts state law requires that the following provider types apply for enrollment in MassHealth to obtain and maintain state licensure.

• Certified Nurse Midwife
• Certified Nurse Practitioner
• Certified Professional Midwife**
• Certified Registered Nurse Anesthetist
• Clinical Nurse Specialist*
• Dentist
• Licensed Independent Clinical Social Worker*
• Optometrist
• Pharmacist (if authorized to prescribe)
• Physician
• Physician Assistant
• Podiatrist
• Psychiatric Clinical Nurse Specialist
• Psychologist*

* Not authorized to prescribe medications

** Certified professional midwives are not subject to the state law requiring providers to apply to enroll.

Claims for services ordered, referred, or prescribed by a clinician who is not a listed provider type must include the NPI of the clinician’s supervising physician (or other authorized ordering, referring, or prescribing provider) on the claim. In that situation, the authorized provider must also be enrolled in MassHealth for the billing provider’s claim to be payable. Note that pharmacy claims must include the individual NPI of the actual prescribing provider.

Required Enrollment for All Providers on Claims

Effective for claims for dates of service on or after January 1, 2027, if state or federal rules require that a provider on a claim submitted to MassHealth must be an enrolled provider, the claim will not be payable if the provider is not enrolled with MassHealth on the date of service (or within 90 days after the first date of service on claims for services that must be ordered, referred, or prescribed). This includes, but is not limited to, ordering, referring, prescribing, attending, supervising, and operating (ORPASO) providers. 

The following table confirms which provider types can be on claims as ORPASO providers. Except for pharmacists who are eligible to prescribe (who may only enroll as “ORPASO only”), all ORPASO providers may choose to enroll as FFS or as “ORPASO only” providers. ORPASO only providers cannot submit claims to MassHealth but may be required to be included on claims submitted to MassHealth under state or federal rules. 

ORPASO Provider Clarifications

Provider Type	May enroll as FFS?	May be on a claim as an Ordering, Referring, or Prescribing provider and are required under state law to apply to enroll?	May be on a claim as an Attending or Supervising Provider?	May be on a claim as an Operating Provider?
Audiologist	Yes	No	Yes	Yes
Certified Nurse Midwife	Yes	Yes	Yes	Yes
Certified Nurse Practitioner	Yes	Yes	Yes	Yes
Certified Professional Midwife	Yes	Yes **	Yes	Yes
Certified Registered Nurse Anesthetist	Yes	Yes	Yes	No
Chiropractor	Yes	No	Yes	No
Clinical Nurse Specialist	Yes	Yes *	Yes	No
Dentist	Yes	Yes	Yes	Yes
Licensed Independent Clinical Social Worker	Yes	Yes *	Yes	No
Optometrist	Yes	Yes	Yes	Yes
Pharmacist	No	Yes***	No	No
Physician	Yes	Yes	Yes	Yes
Physician Assistant	Yes	Yes	Yes	Yes
Podiatrist	Yes	Yes	Yes	Yes
Psychiatric Clinical Nurse Specialist	Yes	Yes	Yes	No
Psychologist	Yes	Yes *	Yes	No

* Not authorized to prescribe medications
** Certified professional midwives are not subject to the state law requiring providers to apply to enroll.
*** Pharmacists must be eligible to prescribe. Pharmacists who have not entered into a Collaborative Drug Therapy Management agreement are not required under state law to apply to enroll in MassHealth. 

Enrollment Instructions

Providers who want to enroll as ORPASO providers should download the ORPASO provider application under Additional Resources and submit their materials to 

MassHealth Customer Service
Attn: Provider Enrollment and Credentialing
P.O. Box 278
Quincy, MA 02171-0005
or fax them to [phone].

Providers who want to enroll as MCE only providers should contact their managed care plan.

Dentists should download the ORPASO provider application under Additional Resources and submit their materials to

MassHealth Dental Program
Attn: Provider Enrollment and Credentialing
PO Box 2906
Milwaukee, WI 53201-290613

To enroll as a MassHealth Fee-for-Service (FFS) provider, apply through MassHealth Provider Self-Service. If you have any questions about the enrollment process, please call MassHealth Customer Service at [phone], TTY/TDD: 711. 

Before you submit your enrollment package, please refer to 130 CMR 450.000: Administrative and Billing Regulations. All portions of these regulations that are not related to billing and payment apply to ORPASO providers. For providers eligible to be FFS providers, please also refer to the corresponding MassHealth provider regulations.

MassHealth will notify you about its decision regarding your application. You are not an FFS or ORPASO provider until MassHealth notifies you that your application has been approved.

Claims Denials

Claims for dates of service on or after January 1, 2027, will be denied if they do not meet the requirement that the ORPASO provider be enrolled with MassHealth on the date of service (or within 90 days after the first date of service on claims for services that must be ordered, referred, or prescribed).

Please note that MassHealth will continue to run informational denial messages related to this requirement for attending, supervising, and operating providers on impacted claims between October 1, 2026, and December 31, 2026.

For more information about the ORPASO requirements, see Additional Resources. 

Additional Resources

Last updated:	October 1, 2026