The Health Plan Identifier (HPID) is a standard, unique health plan identifier number required by the Health Insurance Portability & Accountability Act of 1996 (HIPAA). On September 5, 2012, the Department of Health and Human Services (HHS) published a final rule (CMS-0040F) which required adoption of a unique identifier, the HPID, for Health Plans. The final rule also provided for adoption of the Other Entity Identifier (OEID), intended to be used as an identifier for entities that are not health plans, health care providers, or individuals, but that need to be identified in standard transactions (i.e., a healthcare clearinghouse). The first compliance deadline (November 5, 2014) was for health plans deemed “Controlling Health Plans”, defined as a health plan that controls its own business activities, actions, or policies, or is controlled by an entity that is not a health plan, including self-insured group health plans, with annual receipts in excess of $5 million.

The National Committee on Vital Health and Statistics (NCVHS) is the statutory advisory committee with responsibility for providing recommendations on health information policy and standards to HHS. At a June 10, 2014 NCVHS hearing, the HPID was discussed and strong concerns were raised across the industry regarding a lack of benefit and value in the use and reporting of HPIDs in health care transactions. Specifically, the consensus of the testifiers was that HPID should not be required to be used in administrative transactions and should not replace the payer ID currently used by the health care industry. An analysis by the NCVHS reflected an understanding that the original intent of the use of HPIDs and OEIDs was to identify health plans and clearinghouses to facilitate the routing of transactions to appropriate payer recipients. However, prior to the compliance deadlines the industry itself had already adopted a payer identifier standard based upon the National Association of Insurance Commissioners, and this identifier is now widely used and integrated into all provider, payer and clearinghouse systems. In fact, by modifying the current payer ID system and requiring use of the HPID in its place, it is likely there would be significant disruption in the routing and processing of transactions. Based on the testimony during the June hearing, on September 23, 2014, the NCVHS recommended that HHS:

1.) Rectify in rulemaking that all covered entities (current and future health plans, providers and clearinghouses, and their business associates) will not use HPID in administrative transactions, and that the current payer ID will not be replaced with HPID.

2.) Further clarify in the Certification of Compliance final rule, when and how the HPID would be used in health plan compliance certification and if there will be a connection with the Federally facilitated Marketplace.

In response to those recommendations, the Centers for Medicare & Medicaid Services (CMS), the division of HHS that is responsible for enforcement of compliance with HIPAA, announced on October 31, 2014, a delay, until further notice, of enforcement of the final rule. The enforcement delay applies to all HIPAA covered entities, including healthcare providers, health plans, and healthcare clearinghouses. The result of this announcement means that, for now, HIPAA covered entities need not obtain or use HPIDs or OEIDs.