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
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