Attention All Health Plans: You Must Register for an HPID. Immediately!!!

by Cozen O'Connor
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It has been 18 years in coming, and the time is finally here. All Controlling Health Plans (CHPs) must obtain a unique Health Plan Identifier (HPID). A CHP is a health plan that controls its own business activities, actions, or policies, or is controlled by entities that are not health plans. The HPID is a unique 10-digit, all-numeric identifier that will be assigned to every qualifying health plan.

The Health Insurance Portability and Accountability Act (HIPAA) first indicated the need for HPIDs back in 1996. Almost a decade later, the Department of Health and Human Services (HHS) issued a final rule mandating HPID adoption. Now the important part: the deadline for most providers to register for an HPID is November 5, 2014. (Small health plans, those with annual claims paid of $5 million or less, have until November 5, 2015 to register.)

The primary purpose of HPIDs is standardization, which should make the exchange of electronic data more efficient and more accurate. Among other improvements, HPIDs will drastically decrease the instances of misrouted transactions or rejected transactions due to insurance identification errors. HHS has said that universal adoption of HPIDs is expected to save $6 billion over the next ten years.

While CHPs are required to register, sub-health plan affiliates may register for a HPID or may choose to use the number of its CHP parent. Self-insured group health plans that fit the definition of a CHP will be required to have an HPID. If a health plan engages a business associate to conduct standard transactions on its behalf, the business associate must use the health plan’s HPID in every field where the health plan is identified.

In addition to registering for the HPID, CHPs must disclose their HPID when requested and communicate any changes to the required data elements in the HPID Enumeration System within 30 days of the change.

The HPID will be used for all “standard transactions,” as defined by HIPAA, as well as for other lawful purposes, including: identification on health plans’ internal files; health insurance cards; cross-referencing in health care fraud and abuse files; and identification of health plans on Health Information Exchanges, and federal and state insurance exchanges.

Health Plans can complete their HPID application here.

HHS provides videos to assist Health Plans in the application process and a 111-page User Manual published by CMS here.

 

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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