The Affordable Care Act is presenting employers with new challenges in managing benefit plans. The information in this section will help you stay informed about how to adequately administer your plans.

Health Plan Identifier

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As part of the Administrative Simplification provisions of the Affordable Care Act (ACA), health plans must obtain a unique 10-digit Health Plan Identifier (HPID) number for use in electronic HIPAA transactions.  The goal of the Administrative Simplification provisions is to standardize and simplify electronic data exchange.  HPID numbers will be used to identify health plans in these standardized electronic transactions.

Health plans must obtain a HPID if they meet the definition of a Controlling Health Plan (CHP).  A CHP is one that controls its own business activities, actions, or policies or is controlled by an entity that is not a health plan.  A health plan may also be a CHP if it has a sub-health plan (SHP) and it directs the business activities, actions or policies of the SHP.

Originally, large group health plans were required to obtain an HPID number by November 5, 2014 while small group health plans had until November 5, 2015 to obtain their HPID.  All plans, regardless of size, were to use the HPID in standard electronic transactions by November 7, 2016.

On October 31, 2014, the Centers for Medicare and Medicaid Services (CMS) announced that it is delaying the enforcement of the HPID regulations, including the requirement to obtain an HPID number until further notice.

Additional information is available on the CMS website at: