Health Plan Identifier Deadline Approaching

Large self-funded health plans are required to obtain a Health Plan Identifier (“HPID”) by November 5, 2014. Small self-funded health plans, with annual claims of $5 million or less, have an extra year until November 5, 2015. If an employer maintains a fully insured plan, the insurance company will be responsible for obtaining the HPID.

The HPID is a 10-digit numeric code assigned to health plans in an effort to standardize the transaction process for health care services. For the purposes of the HPID, there are two classes of health plans: (1) controlling health plans (“CHP”) and (2) subhealth plans (“SHP”). CHPs are health plans that control their own business activities or are controlled by an entity that is not a health plan; CHPs are required to obtain HPIDs. SHPs are health plans whose business activities are directed by a CHP; they are not required to get a HPID, but may do so at the direction of its controlling CHP or on its own accord.

In order to obtain a HPID, health plans should apply through HHS’ Health Plan and Other Entity Enumeration System (“HOPES”). In order to do so, an organization must register in the Health Insurance Oversight System (“HIOS”) within HOPES, access the user management role, select the application type, complete the application and have the application reviewed by the organization’s authorizing official. Once this process is completed, and the applications are approved by the organization’s authorizing official, the system will provide a HPID.

The date for full implementation of HPIDs in standard transactions is November 7, 2016. On this date, all covered entities are required to use the HPID in standard transactions involving health plans possessing an identifier. More information concerning HPIDs and the registration process for obtaining one can be found here.

About Jim Hamilton

I am an employee benefits partner with Bose McKinney & Evans LLP. My broad-based practice covers health and welfare arrangements, insurance, executive compensation and federal and state taxation. Among other areas, I have specific experience with PPACA, HIPAA, COBRA, ERISA and numerous other state and federal laws affecting employee benefit plans.
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