Industry Stakeholders Urge CMS to Delay Compliance Date for Health Plan Identifiers

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By James Swann  

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 said the health plan identifier compliance date should be at least Oct. 1, 2015, one year after the ICD-10 compliance date.

AHA also recommended that CMS:

• provide additional guidance on the benefits of adopting a sub-health plan HPID. This option would allow a health plan to define a particular line of business within the overall health plan;

• require nonhealth plan entities that are contractually bound to handle HIPAA transactions to adopt an OEID. Under the proposed rule, the adoption of an OEID is voluntary; and

• require health plans to include their HPID on a beneficiary's health plan enrollment card.


“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.

Additional Time Needed.

The Medical Group Management Association also urged CMS not to maintain the same compliance date for ICD-10 and HPID, as both of the initiatives will require significant resources and time.


“Without appropriately identifying the individual health plan insurance products, ambiguity within the claims revenue cycle will persist.”  


--Medical Group Management Association

“Due to these factors, we strongly encourage CMS to space out the compliance dates for these two mandates and ensure that there is also sufficient time between the compliance dates for ICD-10, HPID and other ACA or HITECH requirements,” Susan Turney, president and chief executive officer of MGMA, said in the group's comment letter. ACA refers to the Patient Protection and Affordable Care Act, and HITECH is the Health Information Technology for Economic and Clinical Health Act.

In addition to delaying the compliance date, MGMA said CMS should pilot test the use of HPIDs among providers, clearinghouses, health plans, and practice management system software vendors.

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 ID Cards.

MGMA also recommended industrywide adoption of a standardized, machine-readable health plan enrollment card. The card would include the HPID, and would save an estimated $2.2 billion a year in administrative costs, MGMA's letter said.

“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.

Opposition to Greater Specificity.

America's Health Insurance Plans said a number of issues merit a re-examination of the HPID compliance date, including the fact that health plans can adopt their HPID starting on Oct. 1, 2012. As a result, “there is unclear expectation as to whether covered entities should use their HPID in transactions or wait until the implementation date (either October 1, 2014 or in the case of small health plans October 1, 2015),” Jeanette Thornton, AHIP's vice president for health IT strategies, said in a comment letter.

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 The AHA comment letter is at The MGMA comment letter is at The AHIP comment letter is at

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