Welcome to this webinar - My name is Kari Gaare and I am a health insurance specialist
in the Office of Ehealth Standards and Services in the Centers for Medicare and Medicaid Services.
This webinar will provide the policy basics for the health plan identifier (the HPID)
and the other entity identifier (OEID). And the registration process
for an account in the Health Plan and Other Entity Enumeration System, which we are calling HPOES.
Since October 1st, those interested in the HPID and OEID
are able to go into HPOES create an account, so they can access educational materials and receive e-mail updates about the HPID and the OEID.
However, applications to obtain the HPID or OEID will not be available until first quarter of 2013.
There have been two webinars in October 2012 about this topic
and we anticipate hosting additional webinars in the coming months that will focus on different subjects related to the HPID and the OEID.
If you are interested in these webinars we encourage you to register for an account in HPOES.
Taking a look at the agenda we will begin with an overview of the HPID and OEID policy
followed by the timelines. Then we will walk through the registration process and finally we will end with next steps .
In terms of background Section 1104 (c) of the Affordable Care Act required the Secretary of Health and Human Services
to establish a unique health plan identifier based on the input of the National Committee of Vital and Health Statistics
with an effective date of October 1, 2012 The National Committee on Vital and Health Statistics held hearings on the health plan identifier in July, 2010.
On April 17, 2012 we published an Notice of Proposed Rulemaking and on September 5, 2012 we published a final rule that adopted a unique health plan identifier
and a data element that will serve as an identifier for entities that need to be identified in the standard transactions
but do not meet the definition of health plan. We will discuss the requirements for both the HPID and the OEID.
So what is the purpose of the HPID? The primary purpose of the health plan identifier is for use in the standard transactions.
Therefore the only required use is that covered entities use HPIDs to identify a health plan that has an HPID in the standard transactions.
While this is the only required use the HPID may be used for any other lawful purpose.For example, a health plan may choose to use an HPID to identify itself on an health plan insurance card.
In order to obtain an HPID an entity must meet the definition of health plan at 45 CFR 160.103.
But because the definition of health plan is very broad we created the definitions of controlling health plan and sub-health plan to differentiate between health plans
that must obtain an HPID and those that are eligible, but not required to obtain an HPID.
We define the controlling health plan as a health plan that controls its own business activities, actions or policies
or is controlled by an entity that is not the health plan.
And if it has a sub-health plan, exercises sufficient control over the sub-health plan to direct their business activities actions or policies.
We define a sub-health plan as a health plan whose business activities actions or policies are directed by controlling health plans.
As you can see on this chart while a CHP is required to obtain an HPID, there would be different options available for the enumeration of SHPs
based on the CHPs organizational structure or needs.
The CHP will need to analyze its organizational structure to determine if and which of its SHPs
need an HPID based on whether the SHP needs to be identified in the standard transactions.
Now well take a look at a specific example. We look at the (NM1) segment in the 2100 A loop that appears in the 270
and 271 X12 version 5010 transactions where the information source is being identified.
The information source as you can see on the screen is defined as the entity that has the answer to the questions being asked in a 270 eligibility or benefit request transaction.
The information source is typically the insurer or the payer. Regardless of the information sources actual role in the healthcare system,
they are the entity who maintains the information regarding the patients coverage.
So an information source could be a health plan or it could be an other entity like a third party administrator.
In this chart, we take a closer look at the transaction to demonstrate how an HPID would be used in the standard transaction.
In NM109 prior to this final rule, a health plan could be identified using a variety of identifiers.
However, after the HPID is required and a cover entity is identifying the health plan only an HPID can be used.
What are we are not requiring. We are not requiring that health plans now be identified in the standard transactions if they were not prior to this rule.
So for instance, in the case of a third party administrator that performs health plan functions on behalf of for instance, a self-insured health plan,
if a TPA and not the self-insured health plan was identified in the standard transactions prior to this rule
then the TPA can continue to be identified in the standard transactions after theHPID is required.
The only requirement is that if a health plan that has an HPID is identified in the standard transactions then it must be identified using an HPID.
So if we think back or think back to the example in the NM109, if the covered entity is currently identifying the health plan as the information source,
the covered entity will be required to use an HPID to identify that health plan as the information source by November 7,2016.
If however the covered entity is currently identifying a third party administrator as the information source.
The covered entity can continue to identify that TPA as the information source using whatever identifier the TPA currently uses
or it could opt to get an OEID and use that after the adoption of the HPID.
So here are the timelines for compliance. Health plans excluding small health plans must obtain an HPID by November 5, 2014.
Small health plans have until November 5, 2015 to obtain an HPID.
Small health plan means a health plan with annual receipts of $5 million or less.
All covered entities will be required to use the HPID and the standard transactions if they are identifying a health plan by November 7, 2016.
So what is the other entity identifier? Essentially, it is just a voluntary identifier for entities that needs to be identified in the standard transactions.
But are not eligible to obtain an NPI, an HPID and they are not individual.
So for instance, a third party administrator could choose to obtain an OEID to identify itself in the standard transactions.
Now, we will take a look at the registration process in the HPOES system. This is a screenshot taken from the Health Insurance Oversight System, which is commonly referred to as HIOS.
HPOES is held within HIOS. What you see here is a HIOS sign in page. For new users who do not already have access to HIOS,
you will need to click on the register for new account link. We will discuss the process for existing HIOS users in a minute. To access the HPOES system please use the URL on this page.
What you see here is the registration page, new HIOS users will need to fill in the required fields in order to submit a request to access HPOES.
A company e-mail address is required as the system will not accept e-mail domain name such as Gmail or Yahoo.
The helpdesk contact information is displayed at the top of the page in case you just have any question or run into issues when filling out the request.
Once you have completed the form, you will click the submit button.Once you have submitted your request you will receive an email that it has been successfully submitted.
All access approval are handled to the HIOS helpdesk. Once an account has been approved, new HIOS users will receive an e-mail notification
with their username, temporary password, and instructions on how to link to the HIOS homepage
For existing HIOS users, you will not need to request access to HPOES because access will be automatically granted.
Next well talk about what users are able to see once they can access HPOES. The sign in page is where both new and existing HIOS users loginto the system.
Youll need to enter your username and password and word verification provided on this page.
When a new user enters the system for the first time they will be prompted to change their password. Once you are logged in, you will see the page that we see now, which is the HIOS portal homepage
Here you can see the system wide announcements, you are also able to navigate to other systems within HIOS.
In addition to new users, existing HIOS users will automatically see the Health Plan and Other Entity Enumeration System button.
Once the button for HPOES is clicked you will be navigated to the HPOES homepage. The homepage has a number of different sections, so Ill describe whats on the page in the next two slides.
As previously discussed, you will not be able to apply for an HPID or an OEID until the first quarter of 2013.
Until that time the HPOES homepage will display information and additional resources. The homepage will include announcements, information and resource section as well as help desk contact information in case there are questions.
The information section provides answers to commonly asked questions and the resource section includes links to the HPID final rule and other helpful resources.
In the upper right hand corner, we want to highlight the education and training section, which will provide information on upcoming events and webinars
On the next page, we see a continuation of the HPOES homepage. Here is a section where you can provide your feedback. If you have any questions regarding the system or how to register, please feel free to reach out to the HIOS help desk
or submit your feedback on this page. We encourage everyone interested in the HPID and OEID to register for an account in HPOES.
If you have any questions regarding the HPID or OEID, please send them to insuranceoversight@hhs.gov.
Thank you for listening to this webinar and be sure to be on the lookout for additional webinars in the coming months that will focus on the HPID and OEID.