Most Health Plans Must Obtain A “Health Plan Identifier”
HIPAA requires that certain information must be transmitted electronically by most health plans. In an effort to create uniformity in the mandatory electronic HIPAA transactions, most health plans must obtain a unique 10-digit identification number. This identification number is called a “Health Plan Identifier” or “HPID.”
Compliance Dates
The deadline to obtain an HPID forhealth plans, except small plans, is November 5, 2014.
The deadline to obtain an HPID for small health plans is November 5, 2015. A small health plan is a plan with $5 million or less in annual receipts.
Beginning November 7, 2016, a HPID must be used to identify a health plan in any mandatory electronic HIPAA transaction.
Applications for an HPID
Health plans must apply for a HPID through the Health Insurance Oversight System of the Centers for Medicare & Medicaid Services. HHS has set up a website to allow health plans to register for and obtain an HPID.
Please note that while the Department of Health and Human Services’ (HHS) regulations explicitly require self-insured plans to obtain an HPID, the application requirements through CMS were designed for fully-insured plans, not self-insured plans. HHS is expected to provide additional guidance before the November application deadline.
Health Plans Required to Obtain an HPID
HHS differentiates between two main categories: Controlling Health Plans (CHPs) and Sub-Health plans (SHPs).
CHPs are required to obtain a HPID. SHPs are not required to obtain an HPID, but may choose to obtain an HPID, or its CHP may obtain an HPID on its behalf.
CHPs are defined as a health plan that—(1) controls its own business activities, actions, or policies; or is controlled by an entity that is not a health plan (2) and if it has an SHP, exercises sufficient control over the SHP to direct its business activities, actions, or policies.
SHPs are defined as a health plan that has its business activities, actions, or policies directed by a CHP.
Use of HPID
HPID will be used in electronic HIPAA transactions. HIPAA transactions include: health care claims, eligibility and benefit inquiry and response, claim status request and response, benefit enrollment, claim payment and advice and premium payment. HPID can also be used for any other lawful purpose that requires the identification of health plans.
For more information, please contact your Trust Fund counsel.
Author: Linda Baldwin Jones
