Tag Archives: HPID

It’s Baaaaack….sort of. CMS Announces RFI for HPID

When CMS published a final rule that outlined specifics around HPID, it caused quite an uproar in the industry.  While CMS thought they were being pretty specific in the rule around a myriad of scenarios, it raised far more questions than it did provided answers.  CMS put HPID on hiatus for a bit considering this mass confusion in from all sides of healthcare.

Late last week, CMS formally announced a Request for Information (RFI) for HPID.  From the press release:

The Department of Health and Human Services (HHS) has released a Request for Information (RFI) on the Health Plan Identifier (HPID). The intent is to collect perspectives from all segments of the industry on the current HPID policy in order to determine future policy directions.

This RFI seeks information from the health care industry about:

The HPID enumeration structure outlined in the HPID final rule, including the use of the controlling health plan (CHP)/subhealth plan (SHP) and other entity identifier (OEID) concepts.
The use of the HPID in Health Insurance Portability and Accountability Act (HIPAA) transactions in conjunction with the Payer ID.
Whether changes to the nation’s health care system, since the issuance of the HPID final rule published September 5, 2012, have altered your perspectives about the function of the HPID.

What are your thoughts?

Breaking News: CMS Delays Usage of HPID

On Friday, CMS announced the delay in the usage and enforcement of HPID in HIPAA transactions.  This is surprising but not at the same time given the ambiguity in how this identifier would be a) enumerated and b) used.

The press release from CMS:

Effective October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) Office of E-Health Standards and Services (OESS), the division of the Department of Health & Human Services (HHS) that is responsible for enforcement of compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) standard transactions, code sets, unique identifiers and operating rules, announces a delay, until further notice, in enforcement of 45 CFR 162, Subpart E, the regulations pertaining to health plan enumeration and use of the Health Plan Identifier (HPID) in HIPAA transactions adopted in the HPID final rule (CMS-0040-F). This enforcement delay applies to all HIPAA covered entities, including healthcare providers, health plans, and healthcare clearinghouses.
On September 23, 2014, the National Committee on Vital and Health Statistics (NCVHS), an advisory body to HHS, recommended that HHS rectify in rulemaking that all covered entities (health plans, healthcare providers and clearinghouses, and their business associates) not use the HPID in the HIPAA transactions. This enforcement discretion will allow HHS to review the NCVHS’s recommendation and consider any appropriate next steps.

Health Plan ID: The Difference Between Health Plan and Payer is Clear as Mud.

When Health Plan Identifier (HPID) first came on the health IT landscape a few years ago, it seemed pretty easy to understand.  It was a part of CMS’ continued administrative simplification effort within healthcare.

Boy were we all wrong.

Last week, Peggy H. and I attended a WEDI Summer Forum held in Minneapolis.  The topics ranged from ICD-10, Attachments, and HPID.  A CMS administrator presented a HPID session via conference call.  However, I think there were more questions and confusion rather than answers.

Over the course of the past few years (and during last week’s sessions), some of the concerns of implementing HPID are as follows:

1) How do health insurance companies (I purposely used this language) enumerate based on the definitions of Controlling Health Plan (CHP) and Sub-Health Plans?  It’s not as easy since this requires a deep dive into how a particular organization is structured.  Are they part of a greater organization with separate corporate entities operating in multiple locations, e.g. states?  That would be require a conversation w/attorneys and the finance folks.

2) Large provider organizations voiced concern about impacts to them.  (This was a complete surprise to me).  A provider may have their general ledger setup w/different health insurance companies they file claims to differently based upon who/how remittances are sent.  Will the right enumerators on claims/remittances be correct or could they potentially mess up a provider’s books?

3) HPID is required on the HIPAA-covered transactions based on how the Final Rule is currently written; however, it has surfaced that CMS may not have intended it to be used on transactions after all.  They apparently want to create a database that lists all payers (or is it health plans????) in a single location.  Uses for this single source of information is pure conjecture at this point.

4) There is a difference in the definition between a ‘health plan’ and a ‘payer’.  I have been in healthcare for over 15 years and in my experience, these two terms are used synonymously.

Gotten your head around any of this?

For the last point regarding the difference in the definition of health plan and payer, WEDI has published an issue brief that explains this further.

Breaking News: CMS Extends Public Comment Period for Health Plan Certification

CMS recently announced they will extend the public comment period for entities that will be defined as a Controlling Health Plan (CHP) for use in HPID and other administrative simplification rules that are on the horizon.  The date was extended to 4/3/14 from 3/3/14.  It appears that TPAs (Third Party Administrators) and self-insured plans and other group-funded plans that previously had been exempt from other HIPAA mandates will now be impacted for HPID.  CMS must have received enough feedback (or lack thereof) from these types of entities to have some concern that they are lagging behind in their understanding of the proposed rules.

Since most federal mandates that affect health IT including HIPAA, administrative simplification, and ICD-10 are rules of law, these means they go through the formal legislative process.  (The children of the 1980’s may recall School House Rock’s ‘I’m Just a Bill’)

And a part of this process means any proposed rules go through the approval process in both houses of Congress and then a public comment period.

HPID: Is There an Alternative Solution?

by Victor Laguardia

As written in previous blog posts, HPID is a major upcoming initiative that is coming down the health IT pike.  However, there is considerable confusion and competing understandings of how this should be implemented.  In this article, the clearinghouse Emdeon has proposed an alternative solution to HPID.  In fact, this solution is not new and first surfaced from Emdeon last year.  There was an industry-wide call setup by the Cooperative Exchange last month where different healthcare entities from clearinghouses, payers, and providers discussed this alternative solution.

Emdeon Alternative Solution–What Is It???

Emdeon presented to WEDI an alternative solution to the use of HPID on the 5010 transactions. This alternative is meant to be only meant as a recommendation to CMS and not indicative that Emdeon will not implement HPID. Following is a summary of their recommendation:

  • Leave Payer information as it is today.
  • Remove all references to HPID from the TR3 Payer Information Segments of 5010 transactions.
  • Use the REF for Subscriber additional information to carry Health Plan ID associated with the claim.
  • In the 271 (Health Plan Eligibility Response) 2100 Subscriber Additional Identification Segment REF01 value ‘18’ Plan Number, add a code note to indicate the Plan Number is the HPID.

Emdeon’s approach would only use the HPID in the eligibility response and look at the ABY qualifier (Centers for Medicare and Medicaid Services Plan ID) for future versions.  The change came about from conversations with ASC X12 who felt that the ABY in the REF01 Element would require Errata (The Errata is created by ASC X12 to resolve impediments to implementation identified after the publication of the TR3s) and would be much more invasive.

WEDI’s Recommendation

WEDI, as an industry organization, has been real careful not to explicitly endorse Emdeon’s alternative HPID solution.  However, WEDI informs CMS of major dialogue and discussions that are occurring in regards to major health IT initiatives.  WEDI communicated to CMS this alternative HPID solution back in October of 2013.  WEDI will forward this alternative solution again to CMS at behalf of the HPID industry workgroup.  This, however, still does not constitute a WEDI endorsement of this HPID alternative solution.