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Final Rule for National Unique Health Plan ID n late August 2012, the Department of Health and Human Services (HHS) ďŹ nalized a rule adopting a standard for the national unique health plan identiďŹ er, or HPID. Additionally, the rule adopts a standard for a data element that will serve as an “other entityâ€? identiďŹ er, or OEID. The rule establishes implementation dates for the HPID. It also addresses some issues related to some prescribers who currently do not have a national provider identiďŹ er (NPI). Lastly, the rule changes the compliance date for the International ClassiďŹ cation of Diseases, 10th Revision, Clinical ModiďŹ cation (ICD-10-CM) for diagnosis coding from Oct. 1, 2013, to Oct. 1, 2014. The complete rule may be downloaded from the following website: 2012-24329_PI.pdf.


The rule was developed by the OfďŹ ce of E-Health Standards and Services (OESS) as part of its ongoing role, delegated by HHS, to adopt standards for electronic healthcare transactions under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). OESS is part of the Centers for Medicare & Medicaid Services (CMS). The adoption of the HPID implements an administrative simpliďŹ cation provision of the Affordable Care Act (ACA). The bottom line for pharmacy? It’s good news. The ďŹ nal rule mirrors the April 2012 proposed rule in not requiring HPID to replace the bank identiďŹ cation number/issuer identiďŹ cation number (BIN/IIN) and the processor control number (PCN). Pharmacy had requested an exemption to the HPID requirement. In adopting the rule, HHS noted that it considered testimony given 44


Marsha K. Millonig, R.Ph., M.B.A.

HHS also considered NCVHS recommendations that a HPID-only requirement would              were working effectively. by NCPDP and others at the July 2010 National Committee on Vital Health Statistics (NCVHS) Subcommittee on Standards meeting on the HPID, and subsequent NCVHS recommendations. At that meeting, NCPDP testiďŹ ed that the use of the BIN/IIN and PCN identiďŹ ers has been very effective in ensuring efďŹ cient, timely prescription claim processing. Additional testimony at the meeting noted that the HPID, BIN/IIN, and PCN identiďŹ ers convey different information and serve different purposes. The rule explains that “the BIN/IIN and PCN identiďŹ ers cannot

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