Under HIPAA, plans that provide health benefits are required to conduct electronic transactions using standards and code sets designated by the Department of Health and Human Services (HHS). The Affordable Care Act added new requirements to those electronic transaction rules, including a requirement that HHS issue rules for a national Health Plan Identifier number (HPID) and a requirement that health plans make a one-time certification that they are in compliance with all of these transaction rules.
For insured health plans, transactions will be identified by the health insurer’s HPID. For uninsured plans, for the most part, as your TPA, we handle these “standard transaction” responsibilities for your health plan . However, under new rules issued by HHS, each health plan must register for its own HPID and obtain certification that its standard transactions are being conducted under the required transaction rules, even if a TPA handles all of the transactions.
Plan sponsors must obtain this HPID themselves. TPAs are not permitted to obtain an HPID for them.
HPID filings have been completed for the plans that we administer that are required to obtain an HPID already in 2014. If we administer your plan and you have not yet obtained an HPID, we will work with you next year to obtain an HPID before the November 5, 2015 deadline.
A great deal of guidance remains to be issued on the certification process. As we receive additional guidance we will work with you to make the required certification.