Health care providers, health plans, or health care clearinghouses would obtain an employer’s EIN directly from the employer. The proposed rule would require an employer to disclose its EIN, upon request, to any entity that conducts standard electronic transactions that require that employer’s identifier. The authority to require this disclosure is implicit in HIPAA’s directive to the Secretary to adopt an employer identification number for use in the health care system. We have identified no reason for an employer to refuse to furnish the number. The EIN, unlike the Social Security Number, is not information about a person. EINs are not considered private and they may be freely exchanged by employers and others.