regulations issued by HHS in 2012, all group health plans must apply
to the Centers for Medicare & Medicaid Services ("CMS")
for a 10-digit health plan identifying number ("HPID"). The
HPID will be used to identify a group health plan when it engages in
Background. HIPAA requires HHS to establish uniform standards for
electronic transactions between group health plans and health care
providers such as doctors, pharmacies, and hospitals. In 2012, HHS
issued final regulations to implement this mandate. In particular,
the final regulations require all health plans to use an HPID in
self-funded group health plans must apply for an HPID by November 5,
2014, while small self-funded group plans (i.e., those with
annual claims of $5 million or less) have an additional year to
obtain their HPIDs. Insurers will apply for HPIDs on behalf of fully
Process. To obtain a
HPID, a health plan's representative must apply through CMS's Health
Plan and Other Entity Enumeration System ("HPOES"). To do
so, an organization must use the following application process:
- register with the Health Insurance
Oversight System ("HIOS") via HPOES;
- access the user management role;
- select the application type;
- complete the application; and
- have the application reviewed by the
employer's authorizing official.
Once this process
is completed, the system will issue an HPID for the group health plan.
NOTE: An authorizing official is an executive of the plan
sponsor who has authority to enter into binding legal agreements on
behalf of the plan.
Using the HPID. Group health plans are not required to begin using
HPIDs in standard electronic transactions until November 5, 2016.
However, group health plan sponsors are advised to begin furnishing
their HPIDs to third party administrators and other business
associates in advance of this date so that they can begin to
incorporate the HPID into their administrative systems and processes.
Group health plan
sponsors may use the HPID to identify the group health plan in
circumstances other than standard transactions. For example, plan
sponsors may incorporate the HPID into the plan's internal records or
membership cards, or in material available to health care providers.
The CMS Health
Plan Identifier webpage has helpful information, including detailed,
step-by-step instructions on how to apply for an HPID. The CMS
webpage can be accessed at: http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Health-Plan-Identifier.html