Health Plan Identifier

On the eve of the HPID November 5, 2014 deadline, CMS announced that enforcement of the HPID requirements is delayed, until further notice.

“Effective October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) Office of e-Health Standards and Services (OESS), the division of the Department of Health & Human Services (HHS) that is responsible for enforcement of compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) standard transactions, code sets, unique identifiers and operating rules, announces a delay, until further notice, in enforcement of 45 CFR 162, Subpart E,

Continue reading Client Alert: HIPAA HPID Deadline Delayed until Further Notice

The deadline for a large health plan to obtain its health plan identifier (“HPID”) is quickly approaching. As we previously advised (please see our Client Alert dated April 21, 2014), the Patient Protection and Affordable Care Act requires a controlling health plan (“CHP”) to obtain a HPID, which must be used in any HIPAA electronic covered transaction that the health plan conducts or that a business associate conducts on behalf of the health plan. The term “controlling health plan” or “CHP” means a health plan (as defined by HIPAA) that (1) controls its own business activities, actions, or policies; or (2) (i) is controlled by an entity that is not a health plan; Continue reading Client Alert: HIPAA Deadline to Obtain Health Plan Identifier Quickly Approaching