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Health Plans to Get Standard ID Numbers

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The U.S. Department of Health and Human Services (HHS) has kept the Web glowing by releasing another batch of major regulations.

HHS put an item on the to-do list of every U.S. health plan by issuing a final rule that will create a national unique health plan identifier (HPID) number and set the requirements for implementing the HPID system. 

HHS also created a data element that will serve as an “other entity identifier” (OEID) that will help the plans, health care providers and others keep track of entities that need to be identified in standard health care transactions and are not plans, providers or patients.

HHS went on to ease the terror some health care organization executives and information technology (IT) managers have been experiencing by pushing the compliace date for a shift to the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM), from the current standard, ICD-9, to Oct. 1, 2014, from Oct. 1, 2013.

Health insurers and many health care providers have generally supported the idea of moving to the ICD-10 system, to replace a diagnosis code system based on work done in the 1970s. Policymakers say the coding system shift should make claims much more modern and precise,  help plans identify waste and fraud, and help wellness analysts, disease management program analysts, researchers and others make better use of claims data.

But health care provider IT executives and physician professional societies have argued that the shift will take a massive amount of work and is much to difficult and costly of a job to undertake at a time when the health care system already is struggling to comply with many complicated new Patient Protection and Affordable Care Act (PPACA) provisions.

The department has been working on the ICD shift to implement provisions in earlier laws.

HHS posted a 208-page preliminary version of the HPID and ICD-10 final rule on the Web today. The Federal Register expects to publish the final rule Sept. 5.

Earlier this week, HHS published a final rule on the requirements for Stage 2 of the Electronic Health Records Incentive Program — a program that’s supposed to reward hospitals and physicians that participate in Medicaid and Medicare for making meaningful use of electronic health recrds (EHR) systems, and it also has announced distribution of 8 PPACA health insurance exchange construction grant awards.

The releases of those documents came on the heels of HHS releasing a final description of the PPACA exchange application process.

The HPID System

The HPID system project is part of a project that federal agencies, health insurers and health care provider groups have been working on for years.

Congress included provisions that led HHS to create an employer ID number system and a “National Provider Identifier” (NPI) number in the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

Provider groups and others have complained that health plans still use many different kinds of conflicting ID numbers, such as taxpayer identification numbers, employer identification numbers (EINs) and proprietary codes.

PPACA Section 1104(c)(1) called for HHS Secretary Kathleen Sebelius to bring order to the chaos by coming up with a standardized HPID system by Oct. 1, 2012. Sebelius was supposed to base the system on recommendations from the National Committee on Vital and Health Statistics (NCVHS).

The HPID number will be a 10-digit, all-numeric identifier with a Luhn check-digit as the 10th digit, according to the version of the final rule now up on the Web. The check digit is a number that can be used to verify whether the card number appears to be correct, officials say.

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.”


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