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December 2014: Health Plan Identifier(HPID) Delayed

The Administrative Simplification Provisions of the Affordable Care Act (ACA) adopted new standards and operating rules for how electronic transactions are conducted among HIPAA-covered entities. These entities include health plans, claims clearinghouses and healthcare providers. Part of this provision included obtaining a Health Plan Identifier (HPID), which is a 10-digit unique health plan number. This requirement has been delayed.


To whom does this apply?

This regulation applies to Controlling Health Plans (CHPs). CHPs are defined as health plans that control their own business activities, actions or policies. Health plans that are self-funded may meet this definition. We recommend that plans confer with their legal counsel to assess whether the new CHP rules apply to them.


What steps do entities need to take to comply?

At this time, no action needs to be taken while we await further guidance from Centers for Medicare and Medicaid Services (CMS). While the original deadlines for obtaining a HPID were November 5, 2014, for large controlling health plans and November 5, 2015, for small controlling health plans, CMS issued a delay, until further notice, of the requirements to obtain and use a HPID. If your health plan has already obtained a HPID in anticipation of the original November 5, 2014 deadline for large CHPs, you may want to keep it on file in the event this number is required in the future.


Whom should I contact with questions? You can contact your Client Relationship Manager with questions.


Compliance Quarterly is being provided as an informational tool. It is recommended that plans consult with their own experts or counsel to review all applicable federal and state legal requirements that may apply to their group health plan. By providing this publication and any attachments, Meritain Health is not exercising discretionary authority over the plan and is not assuming a plan fiduciary role, nor is Meritain Health providing legal advice.