The Centers for Medicare & Medicaid Services should delay the Oct. 1, 2014, compliance date for health plans to adopt unique health plan identifiers (HPIDs), some health industry associations said in comment letters submitted in response to a CMS proposed rule.
The proposed rule, published April 17, would require health plans and organizations such as third-party administrators and clearinghouses to adopt a unique 10-digit identifier for all Health Insurance Portability and Accountability Act (HIPAA) transactions. It would also delay implementation of the International Classification of Diseases, 10th Revision (ICD-10) code set by one year (see previous article).
AHA said the health plan identifier compliance date should be at least Oct. 1, 2015, one year after the ICD-10 compliance date.
The American Hospital Association, while supportive of the health plan identifier concept, said the current compliance date should be delayed so as not to coincide with the revised ICD-10 implementation date, which the proposed rule calls for extending by one year to Oct. 1, 2014.
The proposed HPIDs would standardize the identification of health plans in all HIPAA transactions, with a unique identifier being assigned to each health plan or other organization. Currently, there is no uniform standard for identifying health plans.
“Introducing the HPID and OEID [other entity identifier] at the same time as ICD-10 will make it difficult to determine the cause of any claim delays,” Rick Pollack, AHA executive vice president, said in a letter released on the date comments were due to CMS, May 17.
AHA also recommended that CMS:
“We anticipate that the enumeration system will allow a provider to not only identify a health plan's HPID but to provide corresponding routing and contact information. The enumeration system should help reduce the number of failed attempts providers experience when submitting a transaction,” the AHA letter said.
“Without appropriately identifying the individual health plan insurance products, ambiguity within the claims revenue cycle will persist.” --Medical Group Management Association
MGMA also said CMS should ensure there is more specificity to the HPID, rather than requiring health plans to adopt one HPID covering every individual insurance line.
“Without appropriately identifying the individual health plan insurance products, ambiguity within the claims revenue cycle will persist,” the MGMA letter said.
MGMA surveyed more than 480 practice administrators in 2010, the letter said, and 84 percent agreed or strongly agreed that the entity receiving a claim, such as the primary or secondary health care plan, should have an HPID, and 81 percent said the entity funding a claim, such as an employer health plan or government health plan, should also have an HPID.
“Machine-readable cards, linked to providers' computer systems via a card reader, would lead to automatic, accurate and cost-effective collection of patient information with the simple swipe of a card or scan of a bar code,” MGMA said.
MGMA's 2010 survey of practice administrators found that 70 percent said it would be helpful to have an HPID included in a machine-readable health plan enrollment card.
AHIP also said it was concerned that HPID compliance would be occurring at the same time as ICD-10 compliance.
Regarding the specificity of HPIDs, AHIP said it supported the CMS position that more granularity is not needed.
“A more granular approach would add significant administrative costs to the implementation of HPID and would require the creation of a clearinghouse to maintain a myriad of separate identifiers with little gain for providers, vendors, and health plans,” the AHIP letter said.
CMS should also make clear that any use of an HPID beyond a HIPAA transaction is optional, and that an HPID should not be required on a health plan enrollment card, AHIP said.
By James Swann
The health plan identifier proposed rule is at http://www.gpo.gov/fdsys/pkg/FR-2012-04-17/pdf/2012-8718.pdf. The AHA comment letter is at /uploadedFiles/Content/News/Legal_and_Business/Bloomberg_Law/Legal_Reports/AHAComments(1).pdf. The MGMA comment letter is at /uploadedFiles/Content/News/Legal_and_Business/Bloomberg_Law/Legal_Reports/MGMA-ICD10-HPID-Comment-Letter-2(1).pdf. The AHIP comment letter is at /uploadedFiles/Content/News/Legal_and_Business/Bloomberg_Law/Legal_Reports/AHIP-Comments-HPID-and-ICD-10-5-17-122(1).pdf
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