HEALTH PLAN IDENTIFIER (HPID)
Health Plan Identifier (HPID)
The U.S. Department of Health and Human Services (HHS) has published the final rule addressing the adoption of a unique standard Health Plan Identifier (HPID) for use in HIPAA standard transactions, effective Nov. 7, 2016. To comply, self-funded health plans, excluding small health plans, must obtain an HPID by Nov. 5, 2014. Self-funded small health plans must obtain an HPID by Nov. 5, 2015. (HIPAA defines a small health plan as one with annual receipts of $5 million or less.)
What is a HPID?
Beginning Nov. 7, 2016, health plan’s HPID must be used when the health plan is identified in a HIPAA standard transaction. It is intended to provide consistency and a standard format for health plans to identify themselves.
Two new categories of plans
Two new categories of health plans, as defined in the HIPAA regulations, are:
Controlling Health Plan (CHP)
A CHP is a health plan that:
- controls its own business activities, actions or policies; or
- is controlled by an entity that is not a health plan;
- if it has a subhealth plan(s), exercises sufficient control over the subhealth plan(s) to direct its business activities, actions, or policies.
Subhealth Plan (SHP)
A SHP is a health plan that has business activities, actions or policies directed by a controlling health plan.
What types of plans must obtain a HPID?
All controlling health plans are required to obtain a HPID.
Compliance
The following chart outlines the required time frames for compliance with HPID requirements.
Entity Type |
Compliance Date for Obtaining HPID |
Full Implementation Date |
Health plans, excluding small health plans |
Nov. 5, 2014 |
Nov. 7, 2016 |
Small health plans |
Nov. 5, 2015 |
Nov. 7, 2016 |
Covered healthcare providers |
Not applicable |
Nov. 7, 2016 |
Healthcare clearinghouses |
Not applicable |
Nov. 7, 2016 |
Note: When the HPID application asks for a Payer ID, Trustmark Health Benefits clients should type, “Not applicable.”