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ACA Administrative Simplification Provisions for Health Plans: Time to Apply for an HPID and Prepare for Certification of Compliance
Alston & Bird LLP Link to more items from this source
[Guidance Overview]
Sept. 14, 2014
"The level of control a plan has over its own activities determines whether it must apply for its own HPID or whether it might be able to rely on the HPID of another health plan. If the HPID requirement applies, large health plans must obtain one by November 5, 2014, and small health plans must do so by November 5, 2015. In addition, HHS has issued proposed regulations regarding the 'certification of compliance' with HIPAA's electronic transaction standards required by ACA Section 1104(h). Most health plans must file the first of two certifications with HHS by December 31, 2015. While much detail regarding this certification remains to be developed, health plans should begin planning so that they can complete the certification's required testing process when final regulations are issued."

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