Reform Alert - News from the Blues' Office of National Health Reform

CMS announces delay in enforcement of Health Plan Identifier (HPID) regulations

November 5, 2014

On Oct. 31, 2014, the Centers for Medicare & Medicaid Services (CMS) issued a delay in the implementation of the regulations surrounding Health Plan Identifiers (HPID), including enumeration and use of a HPID.

What is a health plan identifier?

A health plan identifier, or HPID, is a 10-digit number assigned to health plans by the Centers for Medicare and Medicaid Services.

What is enumeration?

Enumeration is the process of obtaining a HPID. All Controlling Health Plans must enumerate. Third-party administrators are not eligible to obtain HPIDs for themselves, but may submit HPID requests on behalf of their health plan customers.

What does this mean for the Nov. 5, 2014, deadline?

The deadline for controlling health plans to obtain a HPID by Nov. 5, 2014, is delayed until further notice.

Who does this apply to?

The enforcement delay applies to all HIPAA covered entities, including healthcare providers, health plans and healthcare clearinghouses.

Are fully insured groups required to obtain an HPID?

Blue Cross Blue Shield of Michigan and Blue Care Network are the controlling health plans for fully insured groups; therefore, fully insured groups are not required to obtain an HPID.

How will self-funded groups know if they are compliant?

Self-funded businesses should consult with their legal counsel about meeting the controlling health plan requirements, their need to obtain a HPID and compliance with the HPID federal mandate.

What happens next?

We are waiting for additional guidance from the Department of Health and Humans Services and will share that with you when we receive it.

More information can be found at:

The information in this document is based on preliminary review of the national health care reform legislation and is not intended to impart legal advice. The federal government continues to issue guidance on how the provisions of national health reform should be interpreted and applied. The impact of these reforms on individual situations may vary. This overview is intended as an educational tool only and does not replace a more rigorous review of the law’s applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. As required by US Treasury Regulations, we also inform you that any tax information contained in this communication is not intended to be used and cannot be used by any taxpayer to avoid penalties under the Internal Revenue Code.