The Health Insurance Portability and Accountability Act

HIPAA REGULATIONS: UNIQUE IDENTIFIERS

HIPAA specifies the development of a common national identifier scheme for providers, employers, health plans and individuals. Of the four types of unique identifiers described in the legislation only two rules have been proposed thus far, those being the rules for an Employer Identification Number (EIN) and the National Provider Identifier (NPI).

On July 30, 2002, DHHS published a final rule in the Federal Register adopting the EIN, issued by the Internal Revenue Service, as the Standard Unique Employer Identifier for use by healthcare organizations for transactional purposes. The compliance date for the EIN is July 30, 2004.

The proposed NPI rule establish requirements that all covered entities (Healthcare Providers, Health Plans and Healthcare Clearinghouses), executing electronic transactions, would have to meet to comply with the unique identifier statutory requirements for electronic transactions. The proposed NPI would be an 8-position alphanumeric identifier that includes a numeric check digit to assist in identifying invalid identifiers. This format would allow for approximately 20 billion unique identifiers to be created.

The proposed rule also calls for the National Provider System (NPS) to issue NPI's based on information entered and maintained by enumerators. These enumerators would enter, validate and update provider data, as well as notify providers of their NPI assignment.

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