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Must Our Group Health Plan Obtain a Health Plan Identifier (HPID)?

EBIA  

EBIA  

QUESTION: Is our group health plan required to obtain a health plan identifier (HPID)?

ANSWER: The HPID requirement was rescinded in October 2019, so it is not necessary (or possible) for health plans to obtain HPIDs.

As background, HIPAA’s administrative simplification provisions included a requirement for HHS to establish standard unique identifiers for each individual, employer, health plan, and health care provider for use in the health care system. After HHS did not act on this requirement, the Affordable Care Act instructed HHS to promulgate a rule establishing HPIDs by October 1, 2012. On September 5, 2012, HHS published final HPID regulations requiring large health plans to obtain an HPID by November 5, 2014. Small health plans were given until November 5, 2015, to obtain an HPID. In addition to HPIDs, the regulations created an “other entity identifier” (or OEID) for non-health plan entities such as TPAs, repricers, and health care clearinghouses.

An enumeration system was subsequently established, making it possible for health plans to obtain HPIDs. However, shortly before the November 2014 deadline for large health plans to obtain HPIDs, HHS announced an indefinite enforcement delay. That delay continued through October 2019, when regulations were issued to rescind the HPID requirement and to eliminate voluntary OEIDs, due to the industry’s adoption of other satisfactorily functioning mechanisms to identify payers; the cost and complexity of implementing HPIDs; and the uncertain value of OEIDs.

When it issued the regulations rescinding the requirement, HHS announced it would no longer accept HPID or OEID applications and would deactivate all previously issued HPIDs and OEIDs. HHS declined to develop policies regarding the use of deactivated HPIDs or OEIDs, but encouraged entities with legacy HPIDs or OEIDs to collaborate and agree on the best identifiers for future transactions.

HHS has noted that two separate statutes still require adoption of some form of unique health plan identifier and asked stakeholders to consider possible business cases for a standard identifier and to share their ideas with HHS. Therefore, while HPIDs are not currently required (or even obtainable), it is possible that some form of identifier for health plans will be mandatory in the future.

For more information, see EBIA’s HIPAA Portability, Privacy & Security manual at Section XXXII.J (“Unique Health Identifiers”). See also EBIA’s Health Care Reform manual at Section XXXII.C (“Expansion of HIPAA Electronic Transaction Rules and Adoption of Operating Rules Under Health Care Reform”) and EBIA’s Self-Insured Health Plans manual at Section XXXI.F (“EDI Standards”).

Contributing Editors: EBIA Staff.

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