Augmenting the Health Insurance Portability and Accountability Act (HIPAA), the Patient Protection and Affordable Care Act (also known as ACA) directed the Secretary of the Department of Health and Human Services (HHS) to issue a Final Rule establishing a standard, unique Health Plan Identifier (HPID). The purpose of a standard HPID is to uniquely identify a health plan in a uniform way in HIPAA transactions.
In order to increase the efficiency of using uniform identifiers in standard transactions, HHS also adopted a data element that will serve as an Other Entity Identifier (OEID). The OEID was intended to function as a voluntary identifier for entities that are not health plans, health care providers, or individuals (as defined in 45 CFR 160.103), but need to be identified in HIPAA standard transactions.
In October 2014, TRICARE successfully submitted for and obtained a Controlling Health Plan (CHP) HPID from the Centers for Medicare and Medicaid Services (CMS) enumeration database. On October 31, 2014, CMS announced a delay in HPID compliance enforcement while it evaluates HPID enumeration and usage. As documented in testimony to the National Committee on Vital and Health Statistics (NCVHS), (1) MHS stakeholders could not identify any unmet business needs related to current use of Payer or Health Plan identifiers, and (2) MHS stakeholders did not find specific benefits to business processes associated with the HPID model established by the HPID Final Rule.
On December 19, 2018, after engaging with HIPAA-covered entities, including MHS, to assess industry needs, CMS released a Notice of Proposed Rule Making (NPRM) that would rescind the adopted standard unique HPID and the implementation specifications and requirements for its use as well as the OEID and implementation specifications for its use.
On 28 October 2019, CMS released a Final Rule to rescind the adoption of these identifiers. The Final became effective on 27 December 2019; after that date, the Health Plan and Other Entity Enumeration System (HPOES) became inaccessible and all HPIDs were automatically deactivated.