Frequently Asked Questions for Sponsors of Self-Insured Group Health Plans

What is the Health Plan Identifier (HPID)?
The HPID is a unique enumerator assigned to a health plan by the Centers for Medicare and Medicaid Services (CMS), part of the Department of Health and Human Services (HHS).

Who must obtain an HPID?
Health plans are required to obtain an HPID. A health plan is “an individual or group that provides, or pays for the cost of, medical care.”
My self-insured group health plan meets that definition. Does it have to obtain an HPID?
Probably not. The federal rules state that only health plans that were being identified in HIPAA standard transactions on the effective date of the final rule (September 5, 2012) must obtain an HPID. In all standard transactions processed by Health New England (HNE), only HNE is identified. Therefore, HNE believes that it is not necessary for each self-insured group to obtain its own HPID.

My self-insured group health plan uses more than one third party administrator. Does that change whether my plan must obtain an HPID?
Maybe. As stated above, health plans that were being identified in standard transactions on September 5, 2012, must obtain the HPID. If your plan uses more than one third party administrator, you should check with your other TPA(s) to determine whether your plan is being identified in standard transactions by any other TPA. If your plan is being identified, you must obtain an HPID.

My self-insured group health plan has determined it is required to obtain an HPID. What is the deadline for doing so?
For a large health plan (annual receipts of more than $5 million), the deadline to obtain the HPID is November 5, 2014. For a small health plan (annual receipts of $5 million or less), the deadline is November 5, 2015.

Is it difficult to obtain an HPID?
It is not difficult to obtain an HPID, but there are several steps involved.
1. You must be registered in the HIOS system maintained by CMS. The HIOS Portal User Manual has step-by-step directions on how to do this beginning on Page 8 of the Manual. Here is the link to the HIOS Portal User Manual: http://www.cms.gov/CCIIO/Resources/Forms-Reports-and-Other-Resources/Downloads/HIOS-Portal-UserManual-082014-150200.pdf
2. Once you have access to HIOS, you then request to have access to HPOES (Health Plan and Other Entity Enumeration System) as a “Submitter.”
3. Once you are approved as a Submitter in HPOES, you access HPOES (by first logging into HIOS) and complete and submit the application for a HPID.

What is the HPID used for?
The HPID is required for use in standard transactions. This is the only required use of the HPID, but it can be used for any other lawful purpose.