HIPAA Standard Identifiers Update

As I blogged this week, August 2006 marks the 10the anniversary of the Health Insurance Portability and Accountability Act (HIPAA) as well as Tiger Woods’ entry into the world of professional golf. HIPAA provides for four standard identifiers to be used with the standard transactions:

1. Standard employer identifier, which is the employer’s employer identification number — the compliance date for use of this identifier was July 30, 2004 (July 30, 2005 for small health plans as defined by HIPAA).

2. Standard provider identifier, which is an “intelligence-free” ten digit number — the compliance date for use of this identifier is May 23, 2007 (May 27, 2008. for small health plans). The National Uniform Claim Committee has created a revised HCFA 1500 claim form (8/05) which incorporates the HIPAA standard provider identifier. According to NUCC’s recommended timeline, health plans, clearinghouses, and information support vendors are expected to be able to receive the revised HCFA form on October 1, 2006.

3. Standard health plan identifier, which has not yet been proposed by HHS., and according to an American Bar Association report, HHS has no plans to issue this identifier in the near future because there is no industry push for this identifier. However, I understand from health plan clients that this identifier would be useful for coordination of benefits purposes.

4. Standard patient (or individual) identifier, which has not yet been proposed by HHS because since 1998 Congress has prohibited HHS from spending appropriated funds on this initiative. However, the day of reckoning may be approaching because the national health information network, a major HHS goal, will need a standard patient identifier or other means of patient identification in order to operate.