The CMS has hit the pause button on enforcing its own rule requiring the use of a national health plan identifier. The rule has garnered industry criticism, so this pause could be recognition that perhaps the rule should be reconsidered.
“There's been a lot of confusion as to the use and purpose of the health plan identifier,” said health information technology consultant Stanley Nachimson, principal of Nachimson Advisors. “The industry has looked at it and said there is no need to use it for the transaction part.”
The Office of E-Health Standards and Services at the CMS announced Friday it would “delay until further notice” enforcement of its 2012 final rule that would require health plans to come up with their own numerical identifiers and also would mandate plans and all other “covered entities,” such as providers and claims clearinghouses to use them.
HPIDs are one of several of identifiers required by the administrative simplification provisions in the Health Insurance Portability and Accountability Act of 1996. A HIPAA-required provider ID was implemented in 2007, but a national patient identifier has remained tabled since 2000 because of privacy concerns.
The CMS delay announcement points to a Sept. 23 recommendation by the National Committee on Vital and Health Statistics, designated an official adviser to HHS by HIPAA, to scrap plans to implement the health plan identifier, since a private industry enumeration scheme is already in place.
The NCHS, in a letter (PDF) to HHS Secretary Sylvia Mathews Burwell, explained that the intent of HIPAA was to use the HPID and “other entity identifiers” to numerically identify health plans and claims clearinghouses “to facilitate routing of transactions to appropriate payer recipients.”
Meanwhile, however, the industry has embraced its own standardized payer identifiers based on the National Association of Insurance Commissioners' identifier. These payer identifiers are “widely used and integrated into all provider, payer and clearinghouse systems,” the NCVHS letter said. These payer identifiers are “currently the basis for routing day-to-day administrative transactions from a provider to the appropriate payer.” Changing the current setup “would create a significant disruption in the routing and processing of all administrative transactions,” the NCHS said.
It called on HHS to “rectify” via rulemaking its own requirement, mandating that all covered entities use health-plan identifiers in HIPAA transactions.
Nachimson said there has been some thought given more recently to also using HPIDs to identify and track health plans participating in Obamacare health insurance exchanges. The NCHS addressed that, too, in its letter to Burwell. It recommended that HHS should further clarify “when and how the HPID would be used in health plan compliance certification and if there will be a connection with the federally-facilitated marketplace.”
Under the CMS' final rule, health plans were to be enumerated by Nov. 5 this year, but HPIDs weren't to be required in common use by covered entities until Nov. 7, 2016.
Acting now, the CMS is actually doing “a good thing,” Nachimson said. “CMS is saying we're not going to enforce until we get some clarification exactly what the health plan ID is being used for.”
Follow Joseph Conn on Twitter: @MHJConn
