Department of Health and Human Services
NATIONAL COMMITTEE ON VITAL AND HEALTH STATISTICS
Subcommittee on Standards
Hearing on the Health Plan Identifier
May 3, 2017
U.S. Department of Health & Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W. Room 800
Washington, D.C. 20201
The National Committee on Vital and Health Statistics Subcommittee on Standards convened a hearing on May 3, 2017 to solicit industry input on the Health Plan Identifier (HPID). The meeting was open to the public and was broadcast live on the internet. A link to the live broadcast is available on the NCVHS homepage, https://www.ncvhs.hhs.gov
Subcommittee Members Present
Nicholas Coussoule, Co-Chair
Alexandra Goss, Co-Chair
Linda Kloss, M.A.
Richard Landen, M.P.H., M.B.A.
Denise Love (via phone)
Debra Strickland
Staff and Liaisons Present
Rebecca Hines, MHS, Executive Secretary, NCHS
Lorraine Doo, MSW, MPH. CMS Lead Staff
Geanelle Herring, M.S.W., CMS
Katherine Jones, M.S., NCHS
Debbie Jackson, M.A., NCHS
Marietta Squire, NCHS
Geneva Cashaw, NCHS
Hearing Presenters List
Madhu Annadata, CMS
Laurie Darst, WEDI
Kelley Turek, AHIP
Gail Kocher, BCBSA
Daniel Sawyer, DoD
Melissa Moorehead, NMEH
Debra Dixon, California Medicaid
Kristy Thornton, PGH (by phone)
Jean Narcisi, ADA
George Arges, AHA
Heather McComas, AMA
Rob Tennant, MGMA
Debbie Meisner, ChangeforHealth
Sherry Wilson, Jopari Solutions on behalf of the CooperativeExchange
Dave Nicholson, CHBME
Laurie Burckhardt, X12
Chuck Jaffe Rep, HL7
Margaret Weiker, NCPDP
Gwen Lohse, CAQH
Nancy Spector, NUCC
Other Participants
Rashida Dorsey, ASPE
Charles Stellar, WEDI
Bob Bowman, CAQH CORE
Gwyn Smith, VA
Carol Wilson, VA
Matt Reiter, HBMA
Gregory Wall, Deloitte Healthcare Informatics
Arianna Simone, Deloitte Healthcare Informatics
Michael DeCarlo, BCBSA
Christine Gerhardt, CMS
Written Comments were provided by:
American Dental Association
ERISA Industry Committee, ERIC
American Hospital Association (AHA)
Medical Group Management Association (MGMA)
National Uniform Billing Committee (NUBC)
American Health Information Management Association-Public Health Data Standards Consortium (AHIMA-PHDSC)
HEARING SUMMARY
THURSDAY, MAY 3, 2017
ACTION STEPS Draft letter of recommendation to HHS Secretary.
WELCOME, INTRODUCTIONS, AGENDA REVIEW
Nicholas Coussoule, Alexandra Goss, Co-Chairs
The co-chairs gave a welcome to all attendees, which was followed by official introductions all all members and other guests present.
The purpose of the hearing was to obtain input from the health care industry for disposition and next steps of the Health Plan Identifier (HPID) following its three year enforcement discretion period. NCVHS has held two hearings on this same topic in 2014, and prepared two letters to the Secretary of Health and Human Services. The Standards Subcommittee intended to secure information from industry regarding the business need and value of the HPID in the current health care environment.
NOTE: For further information, please refer to transcript and PowerPoint presentations.
MORNING SESSION
Overview and Background of the HPID
Madhu Annadata, CMS
Laurie Durst, WEDI
An overview of the Health Plan Identifier policy from a historical perspective was presented to the committee and participants.
PART 1: Health Plans and Providers
Session A: Health plans; private sector, government and self-funded plans provided information about the use, need and purpose of plan identifiers, and the impact of the current HPID final rule, published September 5, 2012.
Commercial Plans: Kelly Turek, AHIP
Gail Kocher, BCBSA
Government Plans: Daniel Sawyer, DoD
Medicaid Plans: Melissa Morehead, NMEH (by phone)
Debra Dixon, California Medicaid (by phone)
Business Groups: Kristy Thornton- PGH (by phone)
Subcommittee Q & A
Discussion began with the request for PBGH to repeat the set of criteria for a health plan identifier enumeration given during testimony. The committee then asked each of the panelists questions intended to gain a better understanding of the current state of health care; and to explain the ways in which the industry assigns payer IDs, how Payer IDs are working to advance administrative simplification when looking at validation for fraud and abuse, meeting the need of purchaser business needs in transparency and how they related to value-based payment initiatives.
PBGH reports that the industry is spending a fortune on attribution and secondary assignment of a payer. Private purchasers are engaged in the alternative payment model work and are challenged by enumeration typologies that exist in the public health field. The current array of identifiers, such as Payer IDs, TINs, NAIC numbers, and EINs do not meet their business need for purposes of alternative payment models.
AHIP advised the panel that they would take the questions posed related to value based care payment models across several payers and how it effects transparency within the area of attribution, as well as the total cost of value based care measurement across payers, back to their members for a more concise response since their testimony centered around the health plan identifier questions posed for this hearing.
BCBSA pointed out to the committee that the issue of the business need for a health plan identifier goes back to the difference between identifying a health plan vs. identifying a payer. BCBSA reiterated that the transactions identify payers, not health plans. The payer information is what goes back and forth within the claim and the claims payment. Providers know which identifier to use based on the destination payer. In most cases, clearinghouses actually handle the transaction processing on behalf of the payer. Health plan identification or the use of health plan identifiers within the current health care environment, would generally be applicable for data reporting. She explained this is why the health plan identifier is not necessary within health care transactions.
NMEH reports having a support group that is working on the difference between the definition of a health plan and a payer. The goal is to seek to get to a granular enough definition of health plan and to understand how to enumerate, particularly in the Medicaid arena.
In light of the testimony that the industry has worked out the claims routing issue with use of the Payer ID within the current health care landscape, the committee questioned whether a solution has been worked out from a systems standpoint in light of the PBGH testimony.
The commercial health plans reported two things: 1-they solved the automation issue for claims administrative processing using PayerID’s, such that any changes to use HPID would add cost with no additional benefit, and 2. attribution of individuals is certainly an issue but not one addressed by HPID that they are not faced with the issue of cost, and the amount of time and energy around attribution. The committee asked whether there is an issue with coordination of benefits. AHIP responded to the committee that the infrastructure built around payer identifiers (the mapping system), which includes the clearinghouses working with payer providers, resolved the initial confusion the industry experienced in the early years of implementation. It is no longer a problem.
Lastly, the committee posed a question about Privacy and Security concerns and HPID in transactions. The committee was advised that the HPID when used in addition to a Payer ID could increase the potential for misrouted claims, and result in a privacy breach if transactions containing PHI are sent to the wrong entity. However, none of the testifiers indicated that there had been problems with such misrouting with the existing process.
Session B— Providers offer their perspective about use, need, and purpose of plan identifiers and impact of the current HPID final rule
Private Sector Providers: Rob Tennant, MGMA (representing other provider associations)
Georges Arges, AHA (by phone)
Government: Katherine Knapp, VA
Subcommittee Q & A Discussion began by committee members asking each panelist their thoughts on health plan identifier enumeration criteria raised by PBGH in their testimony and whether it would have any effect on the providers their groups represent. MGMA raised the issue of health plan auditing in their testimony. Clarifying questions were posed on health plan auditing, such as how the private sector providers envision the health plan identifier would work, and what value the health plan identifier had in certification of health plans or auditing. MGMA reported that in terms of auditing, there is no need for a health plan identifier. Rather, an entity can be picked based on whether a complaint has been filed against them. However, if the only way that HHS can audit a health plan is with a health plan identifier, then panelists advised that the government should move ahead with the health plan identifier. The panelists agree that a health plan identifier is not needed in transactions. MGMA reported that their belief is that more focus should be on encouraging health plans to adopt HIPAA standards and support the operating rules.
The committee posed to the panel the same question asked of the health plans regarding value based purchasing and the alternative payment methodologies models existing in the health care system and how a health plan identifier could work in that environment. The panelists responded that the topic is out scope when looking a health care transactions, which is what their focus was on for today’s hearing. However, they would take some time to research the question and get back to the committee at a future date.
The American Hospital Association (AHA) representative pointed out that a payer typology is a little bit different than the health plan identifier. AHA believes having a payer typology may be beneficial to hospitals. HBMA stated that the need for a health plan identifier within alternative payment models, such as ACOs, patient centered medical homes and/or bundled payments, adds a new layer of complexity. The representative stated that a new identifier would only be beneficial if it gets to the level of the fee schedule or specifics of the contract and not at a general level.
PART 2: Clearinghouses, Vendors and Standards Development Organizations
Session A:
Clearinghouses: Debbie Meisner, Change for Health
Sherry Wilson, Jopari Solutions, on behalf of the Cooperative Exchange (by phone)
Billers: Dave Nicholson, CHBME
Subcommittee Q & A The committee posed a question to the clearinghouse panelists on whether or not tracking is being performed that looks at the number of times there are problems encountered when using the Payer ID for claims payment. Testifiers stated that the Payer ID in the current health care environment is working just fine, but there were some issues that are not technical – such as when a patient presents an old insurance card which results in the claim being routed to the wrong payer.
The committee posed the question to CHBME (Billers) to follow-up to their testimony that suggested there are HPIDs currently flowing through health care transactions. CHBME advised the committee that his organization is linked to a clearinghouse. The clearinghouse representative reported seeing only a few HPIDs within health care transactions. It is possible that the billing organization may be confusing Payer IDs with HPIDs. No follow up was requested on this matter.
AFTERNOON SESSION
Session B:
SDOs: Laurie Burckhardt, X12
Margaret Weiker, NCPDP
Gwen Lohse, CAQH CORE
Nancy Spector, NUCC
George Arges, NUBC – written
Subcommittee Q & A. Questions were posed to the panelists regarding the status of the X12 version 7030 standard – specifically, as to when the public comment period would conclude. The significance of this question pertains to whether there is a business need or requirement for use of the HPID in the transaction. The timing is important for inclusion of the data element in health plan companion guides. X12 advised the committee that at this time they could not provide a date certain as to when X12 version 7030 would begin the DSMO review process. The committee discussed whether a regulation would be needed one way or the other either to upgrade to X12 version 7030, or if X12 would have to create an errata to enable version 5010 to accommodate a mandatory use of the HPID. Ultimately, if HHS remains silent on the HPID (continues enforcement discretion), then the current version of X12 version 5010 can remain in use.
The committee asked a clarifying question to CAQH CORE in order to gain clarity on to what a study as suggested in their remarks would seek to investigate related to health plan identifiers. CAQH CORE reports that as an industry, there isn’t a collective viewpoint on how many IDs or identifiers the industry is using. In addition, there isn’t a validation tool for identifiers. CAQH CORE believes that there is a need to create a validation process tool for identifiers. The committee questioned whether the health information exchanges are doing this sort of work already, and perhaps the issue may be that the HIEs may not be providing the necessary information to the industry.
CAQH CORE also pointed out that their organization is looking at provider patient attribution and the level of identification needed for routing in the system the provider may be using. Many providers are using EHRs to do some of their transactions, however, routing needs are going to be very different in the future, especially if health care moves to a system where patient/provider attribution is needed.
The committee discussed how CAQH CORE’s thinking could change routing and measure system performance. CAQH CORE mentioned that it would be great to hear from some of the larger entities that represent a high percentage of covered entities or covered health plans in order to give this committee a full system picture of how identifiers are given to providers.
Committee Discussion
The committee discussed the themes heard throughout the day. Use of the HPID in electronic transactions is not needed or wanted by the health care industry. The committee discussed declaring that the claims routing issue has been solved. However, what may remain, according to at least two testifiers, is the potential need for a health plan identifier outside of claims routing for future use. The committee deliberated on having this as a potential topic for future work.
The committee discussed the need to keep the two parts of the HPID policy separate and go back to the letter written in September 2014 and start with those recommendations. The committee discussed being more specific in stating what it is being recommend to the Secretary in order to take action in rulemaking. The committee agreed that the testimony was compelling with respect to lack of a use case for the existing HPID Final Rule. It was not designed around the business functions in the current health care environment, nor does it solve the problem it was designed for. However, some organizations identified opportunities for uses of certain types of health plan identifiers, such as in value based purchasing, healthcare research and public health reporting.
The committee also discussed the unintended consequences of rescinding the HPID Final Rule on those entities that have already obtained their HPIDs.
Public Comment
Gwen Lohse, CAQH CORE: Urged the committee to consider the scope of what NCVHS’ responsibilities are and what additional, aggregated data would be useful to NCVHS related to adoption challenges. CAQH CORE implied that additional information might offer more insight into industry needs with regard to identifiers and identification of gaps.
Adjournment: 2:30 p.m.
To the best of our knowledge, the meeting summary is accurate and complete.
Nicholas Coussoule Alexandra Goss
Co-Chair Co-Chair
DATE: June 5, 2017