I’ve posted short and long articles on applying for the HPID, and I’ve warned employers not to wait until the last minute to apply. The Leavitt Benefits Manager (Melissa Handley) and I have spent time over the past month applying for the HPID for the Leavitt Group Health Plan (a self-insured “controlling health plan” or CHP), and on Monday we finally received the email from HIOS that our “application has been processed and approved by the system.” We have an HPID number for our self-insured group health plan!
I must admit that the actual process was more complicated than I imagined while writing the articles– and the articles themselves seemed complicated enough!
So if you can stand to read one more article on the HPID application process, here is my SHORT article with my practical advice.
First, read and print out the two-page instructions/guide from CMS entitled “A Quick Reference Guide to Obtaining a Controlling Health Plan HPID.” It is very helpful to see the screenshots. The Guide is available here: http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Downloads/HPIDQuickGuideSeptember2014.pdf
Second, several things you need to know about the process:
1- In several of the steps, you must complete one step and then wait for a response email from CMS (within 24 hours) before you can proceed to the next step. You can’t just log out and log back in. Your request at one step must be approved before you can take the next step. This is one reason the process takes at least 3-4 days to complete.
2- Some of the steps seem similar and you may think you have already completed one and can’t understand why the system will not let you move forward. Specifically, where I had problems and several clients also have:
- You must request an Issuer role for HIOS
- You must register your organization (group health plan) in HIOS.
- You must request a Submitter role for HPOES
After that you can request an HPID.
Third, here is the process in a nutshell (there are more steps in between, see the Quick Reference Guide):
1- Set up user registration at the cms portal (https://portal.cms.gov ).
2- Log back in to the cms portal and request access to HIOS (see Step 4 of Part 1 in the Quick Reference Guide cited above. The HIOS webpage has green at the top. You will be requesting “New System Access” and “HIOS User” access (Step 5).
- Where you think you need to enter your organization’s EIN as the Authorization Code, you actually need to click on the link right above that and enter information. Within 24 hours you should receive an email approving your HIOS user registration and giving you a HIOS Authorization code.
- You cannot continue to the next step until you receive this email.
3- After you receive the email with your HIOS Authorization Code, log back into the cms portal and you should have a yellow “HIOS” button in the top left screen when you log back in. Click on the yellow HIOS button and then click on “Access HIOS” to get to the HIOS Home Page. (The HIOS home page has green at the top and green rectangular buttons on the left side.)
- The first subheading says “Obtaining a Health Plan Identifier (HPID)” but you are not actually doing that yet. First you need to make sure you have requested and been approved for the Issuer role for HIOS. Click on the green “Role Management” button on the left to see if you are registered as the Issuer. If not, you must do that first.
- This may require waiting another 24 hours for an approving email from cms.
4- Once you receive the response email from CMS, approving your Issuer role request, then you navigate back to the HIOS home page (by now you will recognize it) and register the organization (i.e., your group health plan) in HIOS.
- Click on “Manage an Organization” to do this, and you probably also will need to click on “Create Organization.”
- You might register your organization as “[Employer Name] Group Health Plan” and as an “other entity”—and use your company Federal EIN. This should be the same as on your Form 5500 if you file one.
- Then you must wait 24 hours to receive an email approving your organization request.
5- After you receive the email approving your Organization submission, then you can Request Submitter role for HPOES. It may take up to 24 hours to receive an email approving the Submitter role for HPOES also.
6- After you receive the email approving your Submitter role for HPOES, then you can log back in and request an HPID for your CHP. You will receive an email saying the “CHP HPID application has successfully been submitted”
7- Finally you will receive an email saying “The application has been processed and approved by the system.” And it will give you your HPID!!!
You don’t have to do anything with your HPID yet. You just need to have it by November 5, 2014 (for large controlling health plans, defined as annual receipts of $5 million or more the prior plan year). Small controlling health plans must obtain an HPID by November 5, 2015. The full implementation date for actually using the HPID in standard transactions is November 7, 2016. Also, self-funded plans do not need an HPID in order to set up an account on Pay.gov by November 15, 2014, to submit the annual enrollment count to calculate the Transitional Reinisurance Fee (and pay the first installment by january 15, 2015).