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A Better Partnership


Nov 2014
November 03, 2014

Health Plan Identifier Requirement Delayed Indefinitely

Employers who have not yet obtained a HIPAA Health Plan ID number (“HPID”) for their self-insured health plans can relax: the Department of Health and Human Services (“HHS”) announced on Oct. 31 that it is indefinitely delaying enforcement of the HPID regulations, including the requirement that large self-insured plans obtain an HPID by Nov. 5.

Regulations implementing the Affordable Care Act require that employers sponsoring self-insured health benefits—including medical plans, prescription drug programs, dental programs, vision programs and HRAs that cover more than just deductibles or out-of-pocket costs—obtain a Health Plan ID number. Large plans (those with receipts over $5 million) were required to obtain an HPID by Nov. 5 of this year; small plans (with receipts of $5 million or less) were given an extra year, until Nov. 5, 2015.

For now, these requirements are on hold as HHS evaluates recommendations from the National Committee on Vital and Health Statistics (“NCHVS”) that HHS rework its planned use of the HPID. The NCHVS notes that the medical payment industry has turned to using a standardized national payer identifier based on the National Association of Insurance Commissioners identifier, and that replacing this identifier with the HPID would be disruptive and without any clear benefits.

If your organization has already obtained an HPID, hang on to the information, as the HPID may still end up being used for some purposes. If you have not yet obtained an HPID, you may hold off on applying for the identifier until we get further guidance from HHS.

If you have questions about HIPAA compliance issues, please contact Norbert Kugele ( or 616.752.2186 or April Goff ( or 616.752.2154).

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