Under the Affordable Care Act (ACA), all health plans are required to obtain a Health Plan Identifier (HPID) and use it in transactions with other covered entities. The Department of Health and Human Services (HHS) defines different types of entities that may need to obtain an HPID.
Controlling Health Plan (CHP)
A CHP is a health plan that:
- Controls its own business activities, actions, or policies; or is controlled by an entity that is not a health plan, and
- If it has a subhealth plan(s) (SHPs), exercises sufficient control over the subhealth plan(s) to direct its/their business activities, actions, or policies.
- All CHPs are required to obtain a HPID. CHPs may obtain HPIDs on behalf of their subhealth plans (SHP), or they might direct their SHPs to obtain one.
Subhealth Plan (SHP)
A SHP is a health plan whose business activities, actions, or policies are directed by a CHP. There are different options available for the numbering of SHPs based on the controlling health plan’s organizational structure and business needs. CHPs can decide which of its SHPs need HPIDs, so having a unique HPID for each SHP is optional.
Other Entity Identifier (OEID)
HHS also proposes the adoption of a data element that will serve as another entity identifier (OEID), an identifier for entities that are not health plans, health care providers, or “individuals” that need to be identified in standard transactions (e.g., third party administrators, transaction vendors, clearinghouses and other payers). These other entities would not be required to obtain an OEID, but could obtain one and use it if they needed to be identified in covered transactions between healthcare covered entities.
The HPID rollout follows this implementation schedule.
- November 5, 2012 – Effective date, or the date when health plans could apply to obtain an HPID. This was also when an “other entity” could obtain an OEID.
- November 5, 2014 – Compliance date when large health plans needed to obtain an HPID
- November 5, 2015 – Compliance date when small health plans needed to obtain an HPID
- November 7, 2016 - Compliance date when all covered entities, including health plans, clearinghouses, and health care providers, are to use the HPID in standard transactions.
Self-insured group health plans are included in the definition of a health plan and also need to obtain an HPID if they meet definition of a Controlling Health Plan or CHP described above. Self-insured groups should consult with their legal counsel regarding their HPID status.