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November 5th Deadline to Obtain Health Plan Identifier for Group Health Plans

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The Department of Health and Human Services (HHS) has now issued the final version of its regulations following the passing of the Affordable Care Act (ACA), which will require all group health plans to use a health plan identification number (HPID) to conduct standard transactions.

Do you need to take immediate action?

If you are responsible for a large group health plan – with over $5M in receipts per annum – you must obtain a HPID before November, 5 2014. Small group health plans will also require a HPID, although not for another 12 months. The deadline for small health plans to obtain a HPID is Nov, 5 2015.

The HPID will be required on standard transactions involving the electronic transfer of health data under Health Insurance Portability & Accountability Act of 1996 (HIPAA) regulations. Claims, authorizations, payments and enrolments will all require a HPID, and while group health care plans will not be required to use the identity number until November 7, 2016, a deadline has been imposed on obtaining a HPID number.

CHPs and SHPs

Controlling Health Plans (CHPs) and Sub Health Plans (SHPs) operate on different business models and because of this they are treated differently in the final regulations.

A CHP is in full control of its business activities or – in some cases such as self-insured plans – is not under health plan control. A CHP can have a SHP, provided that it controls the SHP business activities.

Under the new regulations it will be mandatory for CHPs to obtain and use a HPID, while an HIPD for a SHP will be optional. If a CHP controls one or more SHPs, it may obtain HPIDs for each of its SHPs or request that each SHP obtains its own HPID. Alternatively an identity number may be obtained independently by the SHP without CHP instruction.

Who is responsible for obtaining a HPID?

If a fully insured health plan is sponsored by an employer, the insurance provider would be the CHP and would therefore require an HPID. It is important for employers to contact their insurance provider to check that a HPID has been obtained to ensure compliance.

If you are a plan sponsor with a single welfare plan including multiple health plans, a single HPID could be used for all of the plans or each SHD could obtain a separate HPID. Advice and assistance should be sought from the Third Party Administrator (TPA) responsible for the plan.

Deadlines

• November 5, 2014 deadline for group health plans to obtain a HPID (Annual receipts in excess of $5M)
• November 5, 2015 deadline for group health plans to obtain a HPID (Annual receipts less than $5M)
• Covered entities must identify health plans by HPID in standard transactions (under HIPAA) by November 7, 2016
• Compliance certification and attestation requirements must be fulfilled for standard electronic transactions by December 31, 2015. Compliance will be tracked by HPID

If you are a sponsor of a self-insured plan it is important to take action now and speak to your TPA. The TPA will be completing standard transactions and therefore will be responsible for certification on behalf of the plan. Certification requires compliance testing under HIPAA regulations and must be commenced well before the deadline date as it can be a long process.

Information on how to obtain a HPID is available on the Centers for Medicare & Medicaid Services (CMS) website.

Author: HIPAA Journal

HIPAA Journal provides the most comprehensive coverage of HIPAA news anywhere online, in addition to independent advice about HIPAA compliance and the best practices to adopt to avoid data breaches, HIPAA violations and regulatory fines.

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