Benefits and Compensation

Advisory Body Calls for HHS to Rescind Plan Identifier Rule

A federal advisory committee called on the U.S. Department of Health and Human Services (HHS) to rescind a 2012 rule that established a standard unique identifier for health plans.


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A hearing held in May by the National Committee in Vital and Health Statistics (NCVHS) confirmed the emerging industry consensus that HHS’ health plan identifier (HPID) is no longer needed, NCVHS advised HHS Secretary Tom Price in a June 21 letter.

Establishment of the HPID was directed by the Health Insurance Portability and Accountability Act (HIPAA), and reiterated by the Affordable Care Act (ACA), to facilitate the standardization of electronic health care transactions. However, when the rule was set to take effect in November 2014, HHS postponed its enforcement in the face of growing concern from health plans and providers alike.

Testimony at the most recent hearing “overwhelmingly affirmed that there is no longer an industry need for the HPID in the HIPAA standard transaction sets,” according to the letter from NCVHS Chair William Stead. “Testifiers concurred that the transaction routing challenges of two decades ago have been resolved by the industry and that implementation of the HPID would be disruptive, costly, and counterproductive to administrative simplification.”

Therefore, NCVHS recommended that HHS:

  1. Rescind its September 2012 final rule that required health plans to obtain and use the HPID;
  2. Communicate this intention to all industry stakeholders as soon as the decision is made, with guidance on the rescission’s effect; and
  3. Continue its “enforcement discretion” policy until the formal rescission of the rule is published.

NCVHS acknowledged that HHS has had additional uses in mind for the HPID, including enforcement of a proposed requirement for health plans to certify compliance with HIPAA transaction standards. “As industry needs or policy objectives become clearer, NCVHS may consider non-transaction applications of a health plan identifier for consideration in its future work plans,” according to the letter.

The HPID rule established a unique health plan identifier for HIPAA-covered health plans, and an “other entity” identifier for entities like third-party administrators that are not health plans but perform plan functions. Employer-sponsored group health plans (both fully insured and self-insured) were to obtain their own HPIDs.

NCVHS, an advisory committee made up of stakeholders across the health care industry, was designated by HIPAA and the ACA to advise HHS on standard transactions, identifiers, and data privacy issues.

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