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Why an HPID?
In 2012 the Affordable Care Act
required the adoption of a standard Unique Health Plan Identifier (HPID) to be
used in covered HIPAA standard transactions.
There are currently many different health plan number combinations in
regards to length, number and letter combination which can make identification
a frustrating process. The HPID ten-digit
number will be a standardized number to identify a health plan. HHS foresees a publicly accessible searchable
database where these numbers can be looked up for billing information,
eligibility, and other high level information. 1 Part of the complexity with this rule includes an intentional ambiguity on the part of HHS. The goal is for controlling health plans and subhealth plans to obtain an HPID in a way that best fits their business model. 2
Who needs an HPID and when?
Large Health Plans (receipts of $5M or greater) need to
obtain their HPID by November 5th,
2014.
Small Health Plans (receipts of less than $5M) need to obtain their HPID by November 5th, 2015.
Full implementation for using HPID in standard transactions is November 7th, 2016.3
The carriers for most Fully Insured
health plans have or are releasing information about their plans to apply for
an HPID. Self-funded health plans need
to apply for their own HPID if they meet the definition of a Controlling Health
Plan as defined below. 4 Small Health Plans (receipts of less than $5M) need to obtain their HPID by November 5th, 2015.
Full implementation for using HPID in standard transactions is November 7th, 2016.3
Am I a Controlling Health Plan (CHP) or a Subhealth Plan
(SHP)?
Controlling Health
Plan (CHP): a health plan that—
1. Controls its own business activities, actions, or policies; or
2. Is controlled by an entity that is not a health plan; and if it has a subhealth plan, exercises sufficient control over the subhealth plan(s) to direct its/their business activities, actions, or policies.
If either or both of those statements apply to you, you meet the requirements of a Controlling Health Plan.
1. Controls its own business activities, actions, or policies; or
2. Is controlled by an entity that is not a health plan; and if it has a subhealth plan, exercises sufficient control over the subhealth plan(s) to direct its/their business activities, actions, or policies.
If either or both of those statements apply to you, you meet the requirements of a Controlling Health Plan.
Subhealth Plan (SHP):
a health plan whose business activities, actions, or policies are directed by a
controlling health plan. 5
Subhealth Plans are not required to apply for their own HPID. Their CHP may apply for an HPID for their SHP or require the SHP to apply for their own HPID.
Subhealth Plans are not required to apply for their own HPID. Their CHP may apply for an HPID for their SHP or require the SHP to apply for their own HPID.
Commonly Asked Questions:
Q. I got my HPID
number. Now what?
A. The HPID will be used in HIPAA standard transactions so that health plans can be identified.
Q. The HPID Application asks for a Payor ID or NAIC number and I don’t have either? What should I put in the field and will it cause issues with my application?
A. If you do not have a Payor ID or NAIC number, CMS has advised that an applicant fill in “not applicable” in the field. It should not cause issues with your application. If an issue does arise, contact the HIOS Help Desk at 1-877-343-6507 or email at insuranceoversight@hhs.gov.
A. The HPID will be used in HIPAA standard transactions so that health plans can be identified.
Q. The HPID Application asks for a Payor ID or NAIC number and I don’t have either? What should I put in the field and will it cause issues with my application?
A. If you do not have a Payor ID or NAIC number, CMS has advised that an applicant fill in “not applicable” in the field. It should not cause issues with your application. If an issue does arise, contact the HIOS Help Desk at 1-877-343-6507 or email at insuranceoversight@hhs.gov.
Q. How long should the
application take for me to complete?
A. There are 4 steps to the application and you will have to wait to receive approval after each step which can take up to 24 hours at this time.
A. There are 4 steps to the application and you will have to wait to receive approval after each step which can take up to 24 hours at this time.
Q. Under the User
Roles section of the application, am I a Submitter or an Authorizing Official?
A. There are 2 applicable HPOES user roles in regards to completing your HPID application. You can only select to be one role at a time and both roles need to be filled by an applicable party. If you register as a Submitter, you can enter the Authorizing Official’s information on a later screen.
Submitter User: A representative of a health plan or other entity that submits an application.
Authorizing Official User: A company executive that has the authority to approve applications, including CEOs and CFOs.
A. There are 2 applicable HPOES user roles in regards to completing your HPID application. You can only select to be one role at a time and both roles need to be filled by an applicable party. If you register as a Submitter, you can enter the Authorizing Official’s information on a later screen.
Submitter User: A representative of a health plan or other entity that submits an application.
Authorizing Official User: A company executive that has the authority to approve applications, including CEOs and CFOs.
Additional Resources:
http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Health-Plan-Identifier.html
http://www.ncvhs.hhs.gov/
https://portal.cms.gov/
http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Health-Plan-Identifier.html
http://www.ncvhs.hhs.gov/
https://portal.cms.gov/
Sources:
1 Federal Register Vol. 77 No. 172; 45 CFR Part 162
II.2.C
2 NCVHS Meeting Notes from 9/20/12
3 Federal Register Vol. 77 No. 172; 45 CFR Part 162 Chart 1
4 Federal Register Vol. 77 No. 172; 45 CFR Part 162 II.2.A.
5 Federal Register Vol. 77 No. 172; 45 CFR Part 162 II. A.
2 NCVHS Meeting Notes from 9/20/12
3 Federal Register Vol. 77 No. 172; 45 CFR Part 162 Chart 1
4 Federal Register Vol. 77 No. 172; 45 CFR Part 162 II.2.A.
5 Federal Register Vol. 77 No. 172; 45 CFR Part 162 II. A.
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