Beginning November 5, 2014, employers with large self-funded health plans are required by federal government to obtain a national health plan identifier number (HPID). All health plans with more than $5 million in annual receipts must require an HPID, but since health plans don’t have receipts, the Department of Health and Human Services says insured plans should use the premiums from the prior plan year, and self-funded plans should look at claims paid for the prior plan year. Small health plans have an extra year to obtain an HPID with a deadline set for November 5, 2015.

The federal government requires this from all health plans, however, for practical purposes; the insurer will obtain the HPID for those plans that are fully insured. On the other hand, all self-funded plans must obtain an HPID, even if a third party administrator is involved to handle claims.

What exactly, is an HPID?

A health plan identifier number is 10 digits long and consists of only numbers and is used as an identifier for transactions covered by HIPAA.

Why are health plans required to have an HPID?

In an effort to make the claim processing more efficient, the HPID will help with electronic processing and faster automation. HPID’s will be required to be used in HIPPA transactions by November 7, 2016.

How do I know if my health plan is required to have an HPID?

First you must determine which health plan you have. There are two categories of health plans – a Controlling Health Plan (CHP) and a Subhealth Plan (SHP). A Controlling Health Plan is required to obtain an HPID, while a Subhealth Plan is eligible, but not required to get an HPID. To determine whether a Subhealth Plan should get an HPID, the CHP and/or the SHP should consider whether the SHP needs to be identified in the standard transactions. A CHP may get an HPID for its SHP or may direct a SHP to get an HPID. These categories can be confusing, and are intended for insurance companies to determine. If you need help determining which health plan you have, please contact us and we will be happy to help.

If you have a self-funded plan, how does one obtain an HPID?

Employers can apply at the Centers for Medicare and Medicaid Services (CMS) website. It is likely that most employers will be required to register and set up a health insurance oversight system (HIOS) account at https://portal.cms.gov/wps/portal/unauthportal/home/ .

After an account has been established, the employer can register for an HPID. More information on applying can be found here: http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Downloads/HPOESTrainingSlidesMarchSlideDeck.pdf

We are always happy to help, so please contact us if you have any questions or need help obtaining an HPID.