Health Plan Identifier Requirement delayed

November 3, 2014

Enforcement Delayed for Health Plan Identifier Regulations

On October 31, 2014, the Department of Health and Human Services (HHS) announced that, until further notice, it will delay enforcement of regulations related to obtaining the Health Plan Identifier (HPID) and using the HPID in Health Insurance Portability & Accountability Act (HIPAA) transactions that were adopted in the HPID final rule.

This enforcement delay applies to all HIPAA covered entities, including health care providers, fully insured and self-funded health plans, and health care clearinghouses.

The National Committee on Vital and Health Statistics (NCVHS), an advisory body to HHS, issued a written recommendation asking HHS to review the HPID requirement.  The NCVHS recommended that the HPID not be used in HIPAA transactions given that the health care industry has already adopted a “standardized national payer identifier based on the National Association of Insurance Commissioners (NAIC) identifier.”

The NCVHS also outlined issues with the HPID that were raised at its hearings, including:

·         Lack of clear business need and purpose for the HPID

·         Confusion about how the HPID would be used in administrative transactions

·         Challenges faced by health plans defining controlling health plan (CHP) and subhealth plan (SHP)

·         Use of the HPID for group health plans that do not conduct HIPAA standard transactions

·         Cost to health plans, clearinghouses, and providers if software has to be modified to account for the HPID

  What is the Health Plan Identifier?

The health care reform legislation requires all health plans to obtain a ten-digit “unique identifier” from a government sponsored agency, known as the Health Plan Identifier (HPID).  The HPID is intended to streamline electronic transactions between carriers, administrators, health care professionals, and financial institutions.

When obtaining the HPID, health plans are divided into controlling health plans (CHPs) and subhealth plans (SHPs), two terms that were introduced in the final rule.

What This Means

Insured plans and self-funded health plans that have not already obtained an HPID do not need to do so until further notice.  Prior to HHS’s announcement, the following compliance dates were in effect:

·         Health plans with annual receipts of $5 million or more were required to obtain HPIDs by November 5, 2014.

·         Small health plans, defined as plans with annual receipts of $5 million or less, were required to obtain HPIDs by November 5, 2015.

·         All plans that generate the electronic transactions were required to use the identifier in those transactions by November 7, 2016, pending the “operating rules” of the transactional use.

These compliance dates are now delayed, even though the HPID regulations have not specifically changed.  At this time, it is unclear whether or not HHS will adopt the recommendations of the NCVHS on a permanent basis.  In the interim, group health plan sponsors and administrators should stay tuned for further announcements from HHS.

We encourage you to bookmark Cigna’s health care reform website,, where we will update information as more guidance becomes available.