The health plan identifier (HPID) requirement has been rescinded in full.

As background, the Administrative Simplification Rules enacted under the HIPAA law set forth standards relating to privacy, electronic transactions and security of medical information.  A portion of the electronic transaction rules require implementation standards for purposes of streamlining the payment of claims.  Specifically, the law requires health plans to obtain an HPID and other unique identifier requirements for the purpose of streamlining electronic claim processing and other health plan matters.  In addition, the Affordable Care Act requires “controlling health plans” and “subhealth health plans” with an HPID to certify compliance with certain standards for electronic transactions.  The Centers for Medicare and Medicaid Services (CMS) suspended the use of the HPID on October 31, 2014.  Proposed regulations followed in December 2018.  For additional background information, see our prior Benefit Beat articles from 2014: November, October, August and June.  

As a result of comments received in response to the 2018 proposed regulations, CMS issued a final rule on October 28, 2019 rescinding the regulatory requirement for health plans to obtain and use an HPID.  In addition, the final rule also removes the definitions for the “controlling health plan’’ and ‘‘subhealth plan’’.  The final rule takes effect on December 27, 2019.

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