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American Hospital Association Opposes HIPAA HPID Use

Earlier this week, the Vice President and Deputy Director of the American Hospital Association (AHA) sent a letter to the Centers for Medicare & Medicaid Services (CMMS) expressing concern over the implementation of Health Plan Identification numbers (HPIDs) and Other Entity Identifiers (OEIDs).


When HIPAA was introduced, it required national identification numbers to be used by healthcare providers, health plans and individuals. A national ID number was introduced in 2004, although the IDs were only for providers, not individuals.

In September 2012, the HPID proposed rule was published, although it took until November 2014 before the rule was finalized. HPIDs and OEIDs will now be required to be used for HIPAA transactions from Nov 7, 2016. It is not a requirement for health plans to be identified in HIPAA transactions, but if they are, from Nov 7, next year a HPID must be used.

AHA States Opposition to HPID Use in HIPAA Transactions


The letter, sent from Ashley Thompson to Andy Slavitt, the acting administrator for CMMS, stated the AHAs opposition to HIPDs & OEIDs. Thompson said “The intent of the HIPAA legislation was to reduce administrative costs and make the process more efficient; the adoption of the HPID within the HIPAA transaction standards does neither.” The fear is that the use of the ID numbers will add a huge administrative burden on HIPAA-covered entities, but will not provide many benefits.

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Many healthcare plans already have plenty of HPIDs but the process of validating those IDs is difficult. In the letter Thompson points out that many health plans have over 60 HPIDs. Adding more would just “create disruption and confusion to the existing system that routes claims.”

A considerable amount of time has passed since the idea of HPIDs was first discussed, and in the years that followed healthcare providers have taken steps to ensure claims are routed correctly. The methods being used may not be standardized, but they do ensure claims are properly routed.

HPID Use in HIPAA Transactions Means More Unnecessary Admin and Higher Costs


HIPAA compliance already requires a considerable amount of resources, and the addition of HPID/OEID is seen as an unnecessary inconvenience. In the letter, Thompson said, “The AHA recommends that the Department of Health and Human Services (HHS) revise the final rule to prohibit use of the HPID/OEID within a HIPAA transaction,” instead Thompson believes the HHS should “allow the use of existing mechanisms to identify health plans.”

While Thompson was critical of the use of HPIDs for HIPAA transactions, she said the AHA was not opposed to the use of HPIDs and other identification numbers in general, in fact, Thomson said “We support alternate uses of the HPID by CMS, such as to implement the certification program for health plan compliance or for adherence to operating rules for HIPAA transactions.”

This use of HPIDs would be highly beneficial, as it would allow healthcare providers to determine which health plans are in compliance with HIPAA transaction standards. It has been recommended that this use of HPIDs should be implemented no later than December of this year.

Author: Steve Alder is the editor-in-chief of HIPAA Journal. Steve is responsible for editorial policy regarding the topics covered on HIPAA Journal. He is a specialist on healthcare industry legal and regulatory affairs, and has several years of experience writing about HIPAA and other related legal topics. Steve has developed a deep understanding of regulatory issues surrounding the use of information technology in the healthcare industry and has written hundreds of articles on HIPAA-related topics.