The Department of Health and Human Services (HHS) recently announced proposed regulations that would establish a unique health plan identifier (HPID) program for health plans. The Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Patient Protection and Affordable Care Act (PPACA) require HHS to adopt standards for electronic health care transactions to more efficiently exchange health information between entities. To date, HHS issued guidance regarding identifier standards for employers and health care providers, but it had not yet addressed the issue for health plans. Currently, health plans are identified in HIPAA standard transactions using multiple identifiers in inconsistent formats, causing health care providers difficulty when processing transactions. Under this guidance, each health plan would need to obtain its own HPID. Each health plan will be assigned a ten-digit code to use in all HIPAA standard transactions. Health plans would receive their HPIDs through an online application process under HHS's enumeration system, which currently assigns identifiers to health care providers. Health plans would assume the cost and obligation to obtain an HPID and implement its use in all HIPAA standard transactions, even though health providers will experience the most benefit through efficiency in processing transactions.
The proposed regulations include self-insured group health plans in the definition of health plans that must obtain an HPID. HHS recognized that self-insured plans often use third party administrators (TPA) such that the plan is not identified in the HIPAA standard transaction. However, based on the potential need for identification, HHS determined that self-insured plans should be subject to the requirement. The regulations also propose allowing other administrators, like TPAs, to voluntarily obtain an other entity identifier (OEID) for use in HIPAA standard transactions in which they are involved. However, even if the TPA chooses to obtain an OEID, the health plan still needs to obtain an HPID. The OEID and/or HPID would then be used in the transaction. The proposed regulations also differentiate between "controlling health plans" and "subhealth plans." A subhealth plan is a plan whose business activities, actions or policies are directed by another, controlling health plan. In that case, the subhealth plan can choose to use the controlling health plan's HPID or obtain a unique HPID.
If finalized, health plans would need to comply with the regulations by October 1, 2014, with a compliance extension for small health plans until October 1, 2015.