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CMS Announcement – Good News for Employers (Until further Notice)
The following announcement was published on the Centers for Medicare and Medicaid Services (CMS) website regarding a delay in enforcement of the HIPAA Health Plan Identifiers (HPID) requirement.

Effective October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) Office of e-Health Standards and Services (OESS), the division of the Department of Health & Human Services (HHS) that is responsible for enforcement of compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) standard transactions, code sets, unique identifiers and operating rules, announced a delay, until further notice, (emphasis added)  in enforcement of 45 CFR 162, Subpart E, the regulations pertaining to health plan enumeration and use of the Health Plan Identifier (HPID) in HIPAA transactions adopted in the HPID final rule (CMS-0040-F).  This enforcement delay applies to all HIPAA covered entities, including healthcare providers, health plans, and healthcare clearinghouses.

On September 23, 2014, the National Committee on Vital and Health Statistics (NCVHS), an advisory body to HHS, recommended that HHS rectify in rulemaking that all covered entities (health plans, healthcare providers and clearinghouses, and their business associates) not  (emphasis added) use the HPID in the HIPAA.

This enforcement discretion will allow HHS to review the NCVHS’s recommendation and consider any appropriate next steps.

What is a HPID?
The HPID is defined by CMS as a 10 digit number assigned to health plans which is designed to increase standardization and help covered entities verify information from other covered entities.  The number is used to identify health plans in standard transactions.

What Do Employers Need To Do?
Employers with the following plans can suspend application for a HPID until further notice by CMS:

  • HRAs that meet the definition of a health plan
    • HRAs with gross receipts (benefits paid in the prior year) in excess of $5 million would need to apply by 11/5/2014.  If the HRA benefits paid in the prior year are less than $5 million the HPID application must be done by 11/5/2015
  • Retiree HRAs
  • Fully insured medical plans (the carrier would be responsible for the HPID)
  • Self-funded health plan that provides or pays the cost of medical care and is a Controlling Health Plan (CHP)
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