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CMS Announces HPID Final Rule Public Commentary Period

By Jacqueline DiChiara

- The Department of Health and Human Services (HHS) released a Request for Information (RFI) earlier this month on the Health Plan Identifier (HPID). HPID – a standard identifier for health plans – is required to be adopted under the Health Insurance Portability & Accountability Act of 1996 (HIPAA). Small health plans must obtain an HPID by November 5, 2015, according to CMS. HHS’s primary objective is to garner a variety of industry-wide perspectives about current HPID policy to best determine the implementation of upcoming policy decisions.

HPID final rule

A 60 day public comment period is underway and closes on July 28, 2015, confirms the Centers for Medicare & Medicaid Services (CMS) within a press release. Comments may be submitted electronically, or via snail mail, express or overnight mail, or hand courier. HHS specifically pursues more information from health plan representatives, covered healthcare providers, and healthcare clearinghouses about how identifiers in electronic transactions are used to determine if future policy changes are indeed warranted.

Comments from the public are additionally vital to collect and analyze because since the HPID final rule was published, the healthcare industry has undergone a variety of changes – specifically implementation of the Affordable Care Act’s (ACA’s) marketplaces. Both the Secretary of HHS, Sylvia M. Burwell, and the staff of the National Standards Group support commentary from every industry sector.

The RFI requests specific information on behalf of the healthcare industry. Such information includes the HPID enumeration structure as outlined within the HPID final rule which in itself contains 4 separate segments. This final rule adopts the standard for a national and unique HPID and launches a series of implementation requirements.

Secondly, it also embraces a data element that functions as what is referred to as an Other Entity Identifier (OEID). OEIDs can be acquired by those individuals not eligible for either a NPI or an HPID, confirms CMS. Although OEID use is not mandatory and there is no regulatory requirement to use OEIDs in connection with standard transactions, they help identify those entities in HIPAA transactions that cannot be categorized as a health plan, provider, or individual.

Third, the final rule helps clarify what specific circumstances and organization covered health care provider must mandate those non-covered individual healthcare providers that prescribe to obtain and disclose a National Provider Identifier (NPI). The final rule also changes the compliance date for ICD-10 from last October to this October. 

Another greater RFI request from the healthcare industry is the use of the HPID within those HIPAA transactions that are connected to the Payer ID. The RFI primarily seeks to better comprehend whether or not various changes to the general healthcare system since September of 2012 – when insurance of the HPID final rule was published – has tangibly transformed collectively trending perspective regarding the HPID’s overall operation and purpose.

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