Health Plan Identifier Rule

The Health Plan Identifier Rule (Administrative Simplification) requires group health plans to get a health plan identifier (HPID) by November 5, 2014 and begin using it in HIPAA transactions by November 7, 2016.

Blue Shield of California has obtained an HPID and is ready for the November 5, 2014 deadline. However, we understand that some of our Administrative Services Only (ASO) plans and fully insured accounts are asking how to comply with the rule. ASOs are also required to do so.


The Affordable Care Act included a provision called Administrative Simplification, which broadens existing requirements under the Health Insurance Portability and Accountability Act (HIPAA) of 1996.

The Administrative Simplification Rules set standards and operating rules for how issuers like Blue Shield of California and other covered entities interact with providers, particularly regarding electronic transactions of information. The ultimate goal of these requirements is to reduce costs by streamlining transactions and making existing standards work more efficiently.

Fully Insured Groups

Fully insured groups that purchase health insurance through Blue Shield of California are not likely to be considered a health plan by HIPAA and are not required to obtain their own Health Plan Identifier. Guidance available on the CMS website may be referenced for groups unsure if they qualify as a health plan as defined by HIPAA.

Self-funded and Shared Advantage Plans

A self-funded plan is a health plan as defined by HIPAA. As a controlling health plan (CHP), self-funded plans will be required to obtain an HPID even if the plan does not conduct any of the electronic transactions and the HPID will not be used for this purpose. Based on our understanding, most self-funded plans will meet the definition of a CHP and need to obtain their own HPID.

The deadline for obtaining an HPID is November 5, 2014. To help health plans, the Center for Medicare and Medicaid Services (CMS) created an HPID website that has information about the HPID, including videos and presentations. The site also includes details about the Health Plan and Other Entity Enumeration System (HPOES). This is the system a self-funded health plan will use to obtain an HPID. Self-funded plans that have specific questions are urged to contact their own legal counsel.
Blue Shield of California’s Response

As a Controlling Health Plan, Blue Shield of California must comply with these mandated requirements. We have obtained an HPID and are compliant with the November 5, 2014 date. Fully insured Blue Shield groups use our HPID. We will not be applying for any HPIDs on behalf of any of our self-funded plans.

The second part of the rule requires the use of the HPID in the HIPAA standard transactions by November 2016. Blue Shield of California will be assessing the implementation of the HPID in the standard transactions in 2015.

Steve Shorr
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