Comments Regarding the Requirements for the Health Plan Identifier

The Association for Community Affiliated Plans (ACAP) thanks you for providing us with an opportunity to comment on the “Request for Information Regarding the Requirements for the Health Plan Identifier.” This RFI was published May 29, 2015 in the Federal Register.

ACAP is an association of 60 nonprofit and community-based Safety Net Health Plans. Our member plans, located in 24 states, provide coverage to more than 15 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP), Medicare Special Needs Plans for dually-eligible individuals, and Qualified Health Plans (QHPs). ACAP plans currently serve approximately one-third of Medicaid and CHIP enrollees who receive coverage through risk-based managed care, including around one-third of all enrollees in the Medicaid-Medicare demonstrations. ACAP plans are members of their communities, partnering with states to improve the health and well-being of their members who rely upon the Medicaid and CHIP programs.

In the solicitation, comments were specifically requested on the issue of “whether changes to the nation’s health care system, since the issuance of the HPID final rule published September 5, 2012, have altered your perspectives about the function of the HPID.” Our response is a resounding yes.

Given the rapid change since the advent of the ACA and the impending implementation of the ICD-10 coding changes, adding a new requirement at this time will increase the amount of confusion and stress on the system. In addition, given that providers are not required to use the HPID, there would be minimal benefit to the system as a whole since TINs and other identifiers are currently working and should continue to work for the foreseeable future.

Again, we thank you for this opportunity to comment on this important RFI. Please feel free to contact me or Deborah Kilstein, our Vice President for Quality Management and Operational Support ( 202-341-4101) if you would like to discuss any of these issues in greater depth.

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