February 2011 Newsletter
Table of Contents
Denial ManagementX Decision Support
Quadax Goes Global
Scheduled Maintenance
Ready for ANSI 5010?
Progress on ICD-10 Transition
National Health Plan Identifier
2011 Quadax Partners Dinner
EDI Employee of the Year
EDI State of the Department
Other News
News Index

February 2011 Newsletter

National Health Plan Identifier

By: Catherine Sicker, Corporate Compliance Officer

Author's pictureThe Patient Protection and Affordable Care Act (PPACA), now more commonly referred to as the Affordable Care Act (ACA), calls for the Secretary of HHS to promulgate a Final Rule to establish a National Health Plan Identifier (NHPI). The identifier is also sometimes referred to as a Health Plan Identifier (HPID). This key piece of HIPAA legislation has been languishing for years, but the ACA has brought it to the forefront of the National Committee on Vital and Health Statistics (NCVHS). In July of 2010, the NCVHS Subcommittee on Standards held their first hearing. They were looking for “industry input related to options, opportunities, challenges, costs.”

On September 30, the Subcommittee made their recommendations to the Secretary, Kathleen Sebelius:

1. Definitions and types of entities eligible for enumeration

  • Clarify the definition of health plan as specified in the HIPAA regulations. Include property and casualty insurers and worker’s compensation plans
  • Reach consensus on names and definitions for intermediary entities

2. Levels of entity enumeration

  • Enumerate all health plan legal entities as defined by HIPAA
  • Determine at what level, including product (benefit package) level or other categorization, a health plan should be enumerated

3. Format and content of HPID

“NCVHS believes there is an opportunity created by the Affordable Care Act to increase adoption of health information technology tools to improve the effectiveness of the health care system. The industry has awaited a national health plan identifier for some time.”

  • Adopt an HPID that follows the ISO Standard 7812, with Luhn check-digit as the tenth digit
  • Adopt an HPID that contains no embedded intelligence

4. Directory database to support the HPID enumeration

  • Establish an enumeration system and process supported by a robust online directory database
  • Identify the minimum necessary data elements for the directory database

5. Retail pharmacy implementation

  • Do not require the HPID to be used in place of the existing RxBIN/PCN identifier in retail pharmacy business and transactions
  • Require the use of HPID on the HIPAA-named standard transactions for retail pharmacy, where appropriately defined by industry through the ASC X12 and NCPDP processes

6. Implementation and timing

  • August 2011 - Publish interim final rule
  • October 1, 2012-March 31, 2013 - Enumeration
  • April 1, 2013-September 30, 2013 - Testing
  • October 1, 2013 - Implementation

7. Testing

  • Provide sufficient time and guidance for testing
  • Allow for a period during which dual use of legacy health plan identifiers and the new HPID is permitted in the transactions

8. Use of the HPID on health plan identification card

  • Encourage the use of the HPID in health plan identification cards

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