November 30, 2021

Volume XI, Number 334


November 29, 2021

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Health Plan Identifier (HPID) Adoption Deadlines Indefinitely Suspended

The U.S. Department of Health and Human Services (HHS) has announced it is indefinitely suspending its rule requiring certain health plans to adopt Health Plan Identifier (HPID) numbers until further notice. 

In general, the HPID is a standard, unique health plan identifier that HHS mandated certain health plans obtain. The requirement, which arose under the Affordable Care Act, was imposed to make more uniform the processing of HIPAA standard transactions. HHS believed that utilizing the HPID could avoid deficiencies related to the improper routing of transactions, rejected transactions due to insurance identification errors, difficulty in determining patient eligibility, and challenges resulting from errors in identifying the correct health plan during claims processing.  

Prior to the suspension, Controlling Health Plans (CHPs) [in general, a plan with annual receipts in excess of $5 million and controls its own business activities or is controlled by an entity that is not a health plan] and Small Controlling Health Plans (SCHPs) [in general, a controlling health plan, but with annual receipts of $5 million or less] were obligated to adopt a standardized HPID by November 5, 2014, and November 5, 2015, respectively. Note, for insured plans, this obligation was generally undertaken by the insurer. 

What do we do now?

With the latest announcement from CMS, however, CHPs and SCHPs are left in limbo as to when they must adopt HPIDs. Entities which have already worked through the process to obtain an HPID will need to evaluate how future guidance may require additional action on their part.  Entities which were working through the process can cease current action and will need to wait for future guidance to determine when to finish the process.

Nevertheless, no plan administrator should take this suspension announcement as an indication of the death of HPIDs. Rather, plan administrators that have not overseen adoptions of a HPID should view the delay as a brief reprieve from enforcement.

©2021 MICHAEL BEST & FRIEDRICH LLPNational Law Review, Volume IV, Number 309

About this Author

Kirk Pelikan, Michael Best Law Firm, Labor and Employment Attorney

Kirk’s practice focuses on legal issues related to all aspects of the employment cycle, from hiring through termination and severance. Substantially experienced in both benefits and employment law, Kirk is well positioned to help clients respond to the opportunities, vulnerabilities and benefit ramifications of particular employment decisions.

Kirk’s focus includes:

  • Developing and maintaining effective compliance strategies related to defined benefit plans, defined contribution plans, executive...