Plan sponsors of group health plans should be aware that the Centers for Medicare & Medicaid Services have begun accepting applications for Health Plan Identifiers, or “HPIDs.” An HPID is a unique identifier that is intended to increase standardization within HIPAA standard transactions. Most group health plans must obtain an HPID by Nov. 5, 2014. Note that small health plans, which are health plans with annual receipts of $5 million or less, do not have to obtain HPIDs until Nov. 5, 2015.

Action Items

  • Review and revise, if necessary, notices of privacy practices and HIPAA policies and procedures to reflect the terms of the final rule.
  • Understand HIPAA’s new breach notification standard and make any necessary changes to policies and procedures. 
  • Review existing business associate agreements to determine whether any changes are necessary. 
  • For business associates, determine whether any subcontractors or vendors are now considered business associates that require their own business associate agreement.
  • Revisit plan design to ensure that, for the plan year beginning in 2014, the plan does not impose: annual limits on the dollar value of essential health benefits; waiting periods in excess of 90 days; or pre-existing condition exclusions.
  • Prepare and distribute notice of coverage options and updated SBCs. 
  • Review summary plan descriptions and plan documents to reflect health care reform changes being made under PPACA. 
  • Review policies, procedures, plans and forms to recognize the rights of same-sex spouses under federal law. 
  • Prepare and distribute the Notice of Exchanges.
  • Apply for an HPID.