November 4, 2019

HPID Rules Rescinded

The health plan identifier (HPID) requirement has been rescinded in full.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


The information contained in this article is provided as general guidance and may be affected by changes in law or regulation. This article is not intended to replace or substitute for accounting or other professional advice. Please consult a CBIZ professional. This information is provided as-is with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein.

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