ARTICLE
4 November 2014

Enforcement Of Health Plan Identifier Rules Delayed

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Day Pitney LLP

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The CMS Office of e-Health Standards and Services announced a delay in enforcement of the Health Plan Identifier rules for electronic healthcare transactions.
United States Food, Drugs, Healthcare, Life Sciences
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On October 31, the Centers for Medicare & Medicaid Services (CMS) Office of e-Health Standards and Services (OESS) announced an indefinite delay in enforcement of the Health Plan Identifier (HPID) rules for electronic healthcare transactions. Large employers with self-funded group health plans had been required to obtain HPIDs by November 5, 2014.

The HPID is a unique 10-digit number that all covered entities (health plans, healthcare providers and clearinghouses, and their business associates) were to be required to use in medical and dental claim payments, authorizations, plan enrollments, and other transactions subject to HIPAA. OESS's "Statement of Enforcement Discretion" follows a recommendation on September 23 by the National Committee on Vital and Health Statistics (NCVHS), an advisory body to the Department of Health and Human Services (HHS), that the payer IDs currently used in HIPAA transactions not be replaced with HPIDs.

Self-insured group health plans that control their own business activities, actions or policies are referred to as Controlling Health Plans (CHPs). Under HHS's "health plan enumeration" rules, large CHPs were required to obtain HPIDs by November 5, 2014, while small CHPs were given until November 5, 2015 to do so.

The HPID application process has been widely criticized for its complexity and unclear instructions. The current delay will allow HHS time to review NCHVS's recommendation and determine how to improve the process.

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