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Health Care Reform and the HPID Requirement Delay

Employee Benefits, Medicare

On October 31, 2014, the Centers for Medicare and Medicaid Services (CMS) announced a delay of their current Health Plan Identifier (HPID) requirements. Here is an overview of the HPID requirement.

What is the HPID Requirement?

The Affordable Care Act (ACA) requires Health and Human Services (HHS) to create a process for health plans that use HIPAA standard transactions to have their own unique identifier (Health Plan Identifier “HPID”). The new identifier allows a health plan to be identified within those transactions. On September 5, 2012, HHS adopted the HPID requirement, requiring large health plans to have an HPID by November 5, 2014 and small plans by November 5, 2015. As of now, the deadline has been delayed until further notice.

What were the timelines for obtaining the HPID?

On September 5, 2012, HHS adopted the HPID requirement, requiring large health plans to have an HPID by November 5, 2014, and small plans by November 5, 2015. The HPID requirement uses the HIPAA definition of health plan, which includes self-funded health plans. The rule also adds two additional definitions of “controlling health plan” and “subhealth plan,” as plans that are required (or not required) to obtain an HPID.

On October 31, 2014, The Centers for Medicare and Medicaid Services (CMS) announced a delay “until further notice” of the HPID requirements. The delay was based on a recommendation by the National Committee on Vital and Health Statistics (NCVHS) opposing the implementation of the requirement based on the fact that the industry already has a “standardized national payer identifier based on the National Association of Insurance Commissioners (NAIC) identifier.”

Key Takeaway

All sponsors of self-funded health plans may discontinue their current process of obtaining a HPID for their plan. Sponsors that already received their HPID number should retain their number until further notice.

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