Health Plans to Get Standard ID Numbers

A health plan would apply to get an ID number from an online application process. A help desk or other applicant assistance service is supposed to be available to help with the application process. Managers of the HPID "enumeration system" would be able to deactivate an ID number if a plan changed ownership or restructured, or if some other entity were making unlawful use of the ID number.

The enumeration system managers would collect the minimum amount of information needed to uniquely identify a plan and create links between a top-level health plan, or "controlling health plan" (CHP), and the CHP's "subhealth plan" (SHP) affiliates.

A CHP would have to get an ID number. An SHP could choose whether to get its own number or use the number of its CHP parent.

The compliance date for most plans will be Oct. 1, 2014. For small plans, the compliance date will be Oct. 1, 2015.

The final rule also expands the need for health care providers to get NPI numbers.

Today, officials say, pharmacies are running into problems when physicians or other providers write prescriptions without supplying NPI numbers. Prescribers within health care organizations that must have NPIs may now have to get their own NPIs and disclose those individual NPIs to pharmacies, officials say.

The Comments

HHS officials write in a preamble to the HPID-ICD-10 final rule that they received 536 comments on a draft of the rule posted in April.

Some commenters discussed whether plans ought to put HPIDs on enrollees member ID cards. Some commenters said putting the numbers on cards should be mandatory; others said the cost of re-issuing member ID cards to include the numbers immediately would outweigh any benefit.

"In this rule, we only require the use of the HPID in the standard transactions," officials say. "The HPID is permitted to be used for any other lawful purpose and inclusion of the HPID on health plan members' ID cards is just one example of an optional use of the HPID. While health plans are permitted to put the HPID on member ID cards, we do not require it, so the determination of whether to reissue cards, and the associated costs, lie with the health plans."

Other commenters asked about the OEID numbers and what types of entities, such as such as accountable care organizations and atypical providers," ought to get the numbers.

"Atypical providers are individuals or organizations that furnish atypical or nontraditional services that are indirectly health-care related, such as taxi, home, and vehicle modification, insect control, habilitation, and respite services," officials say. "We encourage entities to review the definition of health care provider … and the discussion of atypical providers in the NPI final rule … in determining their eligibility to obtain an OEID. We decided to place few requirements on entities that obtain an OEID, because we wanted to allow industry business needs to drive industry use of the OEID, presumably through contractual arrangements."

Also in the comments, HHS officials say they pushed back the ICD-10 shift compliance date to give plans time to implement the HPID regulations.

Some commenters suggested that the United States skip ICD-10 altogether and wait to implement the next version of the standard, ICD-11.

"This option was eliminated from consideration because the World Health Organization (WHO), which creates the basic version of the medical data code set from which all countries create their own specialized versions, is not expected to release the basic ICD-11 medical data code set until 2015 at the earliest," officials say. "From the time of that release, subject matter experts state that the transition from ICD-9 directly to ICD-11 would be more difficult for industry and it would take anywhere from 5 to 7 years for the United States to develop its own ICD-11-CM and ICD-11-PCS versions."