On October 31, 2014, HHS announced a delay, “until further notice,” in the enforcement of the regulations pertaining to Health Plan Identifiers (HPIDs) and their use in HIPAA standard electronic transactions. For more information on the HPID requirements, please see our October 1, 2014 SW Benefits Update, “HIPAA Requires Many Health Plans to Obtain a Health Plan Identifier by November 5, 2014.” This enforcement delay applies to all HIPAA-covered entities, including healthcare providers, health plans, and healthcare clearinghouses.
The decision to delay enforcement was based, in part, on a recommendation by the National Committee on Vital and Health Statistics (NCVHS), which is an advisory body to HHS. On September 23, 2014, NCVHS recommended that HPIDs not be used in HIPAA standard electronic transactions, reasoning that the healthcare industry has widely adopted and implemented the use of payer IDs created by the National Association of Insurance Commissioners, making HPIDs unnecessary and disruptive to current industry practice. NCVHS also mentioned the challenges faced by health plans with respect to the definitions of controlling health plans and subhealth plans, and the required use of HPIDs for group health plans that do not conduct HIPAA standard electronic transactions.
HHS may have also decided to delay enforcement due to the difficulties many entities were having in completing the HPID online application. HHS states that it will “review NCVHS’s recommendation and consider any appropriate next steps.”