ACA’s Health Plan Identifier Requirement

As the old saying goes, “the devil is in the details”, and the Affordable Care Act (ACA) has its fair share of DETAILS.  Among the rapidly approaching compliance deadlines for many employers is requesting/obtaining a ten-digit Health Plan Identifier or HPID.   While ALL employers offering health insurance plans must comply with this requirement, the due date for obtaining the ID, along with determining who is responsible for obtaining it varies based on a couple of factors.  Here’s an overview of the whole HPID…

The ACA includes an important section known as Administrative Simplification.  Included in this section is the requirement that virtually ALL health plans obtain an HPID.  At this point, we know HPIDs will be used in making HIPAA related electronic transactions (e.g., medical/dental claims, premium payments, enrollment, disenrollment, etc.).  Further guidance pertaining to the use of the HPID is expected from Health and Human Services (HHS) in the near future.  In the mean time, here is the “when” and “who” affected by this ACA compliance requirement:

WHO:

  • Employer-sponsored group health plans
  • Health insurance issuers and HMOs (NOTE: Employers with FULLY INSURED plans are not required to apply/obtain an HPID.  Rather, insurers will have and use HPID’s on behalf of their employer group customers.)
  • Federal employee health benefits (FEHB) program and governmental health plans; and
  • Controlling Health Plans (CHPs) and Subhealth Plans (SHP)

WHEN:

  • Employers with annual receipts of $5 million or more by: November 15, 2014
  • Employers with annual receipts less than $5 million byNovember 15, 2015
  • Plans generating HIPAA electronic transactions required to use HPID by: November 7, 2017

Partially self funded/self funded employers are thus required to obtain their own HPIDs, and Third Party Administrators (TPAs) and Administrative Services Only providers (ASO) are not allowed to obtain the HPIDs for their customers.  To assist affected employers with this application process, the Centers for Medicare and Medicaid Services (CMS) has developed a variety of resources:

  1. PowerPoint presentation (59 slides) – http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Downloads/HPOESTrainingSlides02132013.pdf?elq=8cf0385af6094e55b17daa7b9297c171&elqCampaignId=1491
  2. CMS website link dedicated to HPIDs – http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Health-Plan-Identifier.html
  3. CMS’ web portal – https://portal.cms.gov/wps/portal/unauthportal/home/

Affected large (i.e., over $5 million in annual receipts), partially self funded employers are encouraged to apply for their HPID as soon as possible.  The application requests an employer’s “payer ID number”; but CMS has advised employers that do not have such a number to enter “not applicable” in this field, and continue with the process.

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