Federal officials should consider making intermediary entities providing services to health plans--such as benefits managers, third-party administrators and repricers--eligible for receiving a unique health plan identification number, according to recommendations recently sent to the Department of Health and Human Services.
The feds also should clarify the definition of "health plan" as specified in the HIPAA regulations, the National Committee on Vital and Health Statistics, an HHS advisory body, recommends. Now that the Accountable Care Act mandates adoption of a unique health plan identifier--as HIPAA did some 14 years ago--the definition of a plan needs updating.
NCHVS in an eight-page letter makes a series of recommendations to HHS as the agency starts work on promulgating a final rule to establish the identifier.
For instance, the identifier should follow Standard 7812 of the International Organization for Standardization with a "Luhn" check digit as the 10th digit, and the identifier should contain no embedded intelligence. Further the identifier should not be used in place of the existing RxBIN/PCN identifier for retail pharmacy business and transactions, according to NCVHS' recommendations.
Text of the letter is available at ncvhs.hhs.gov/100930lt1.pdf.
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