On Halloween, the Department of Health and Human Services announced an indefinite delay in enforcement of the health plan identifier (HPID) rules. As a result, large health plans are no longer required to choose whether to obtain an HPID by this Wednesday, November 5, 2014, or face the prospect of a $50,000 fine. The delay appears to have been motivated by a recommendation from the National Committee on Vital and Health Statistics, dated September 23, 2014, "that HHS rectify in rulemaking that all covered entities...not use the HPID in the HIPAA [electronic] transactions." The Committee had noted that "[a] consistent message heard strongly across the industry...was the lack of benefit and value in the use and reporting of HPIDs in health care transactions," which had been the principal purpose for implementing the HPID rules.
Given the arcane nature of the subject matter, the announcement understandably received little media attention. The reaction from the practitioner community similarly has been muted. It remains to be seen whether an effort will be made to calculate the loss of revenue to the federal fisc as a result of the decision to delay enforcement, or whether the decision will be portrayed as politically motivated given the upcoming mid-term elections.
Bottom line? This month, sponsors and administrators of large, self-insured group health plans should focus on providing accurate census figures for the transitional reinsurance fee assessment, which are due by November 15, 2014.
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