The Affordable Care Act requires large health plans (annual receipts above $5 million) to obtain unique health plan identifier numbers (HPIDs) by November 5, 2014. Small health plans (annual receipts of $5 million or less) have until November 5, 2015, to obtain HPIDs. For fully insured plans, receipts are the total premiums paid for health insurance benefits during the plan’s last full fiscal year. For self-insured plans, receipts are the total amount paid for health claims. By November 7, 2016, all covered entities must use HPIDs to identify health plans in any HIPAA standard transactions.
Health insurance carriers are required to obtain HPIDs for fully insured plans. Employers sponsoring self-insured health plans are responsible for obtaining an HPID for their plans. A health plan may authorize a third-party administrator to obtain an HPID on the plan’s behalf.
Health care flexible spending accounts (FSAs) and health savings accounts (HSAs) are not required to obtain HPIDs. Health reimbursement arrangements (HRAs) may be required to; however, HRAs that cover only deductibles or out-of-pocket costs do not require HPIDs.
The HPID application system is currently open. The application process can be cumbersome, but the website has instructions and videos explaining the process. To obtain an HPID, first register with the Health Insurance Oversight System (HIOS), then complete the HPID application. Existing users of HIOS should already have received an email with new login credentials. The HPID application requires:
- Company name, address, and federal employer identification number;
- Authorizing official information, including first and last name, title, phone number, and email address; and
- The health plan’s NAIC number or payer ID.
Once approved, an email will be sent containing the HPID. Employers who do not perform HIPAA standard transactions may not use the HPID. However, employers should share the number with their plan’s third party administrators and business associates who will use this number.
Click here for more information on HPID requirements.