HIPAA's Unique Identifier Rule mandates the use of standardized, unique codes to identify healthcare organizations, employees, and patients. As part of HIPAA's Administrative Simplification requirements, a regulated identification system enhances efficiency and security in healthcare operations.
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What are unique identifiers?
A unique identifier (UID) is a unique marking that makes a particular record (or object) different from every other. Used early in the development of information systems, UIDs allow records to be referenced easily without confusion. These identifiers can be randomly generated, allocated incrementally, or chosen by a user.
The type of UID depends on its purpose. Think about a string of words (i.e., a URL) for a website or a generated set of numbers for a Social Security Number. A single record may have multiple identifiers depending on who is accessing the information and for what reason.
UIDs improve search methods, allow something to be easily referenced, and simplify tracking. Moreover, they can do so without identifying something specifically not used, like a person's name.
HIPAA and the Unique Identifier Rule
The Health Insurance Portability and Accountability Act of 1996 is U.S. legislation that protects the rights and privacy of patients. The act sets out the rules surrounding access to and disclosure of PHI. Understanding and implementing HIPAA guidelines is fundamental to avoiding data breaches and HIPAA violations.
There are 18 PHI identifiers set out in HIPAA's Privacy Rule that relate and link to patients. When used along with details such as a patient's mental and physical health, any information can be considered PHI. To safeguard PHI, covered entities must comply with all of HIPAA's rules, including the HIPAA Administrative Simplification Regulations.
These policies establish national healthcare standards that save time and costs and keep private information secure. These regulations cover four areas within healthcare: transactions, code sets, operating rules, and identifiers. The Unique Identifier Rule requires healthcare organizations to use several identifiers for the regulation, efficiency, and consistency of healthcare services.
Learn more: What are HIPAA's administrative simplification provisions?
National provider identifier
The national provider identifier (NPI) is a unique 10-digit number assigned to individual healthcare providers and healthcare organizations. NPIs streamline the process of identifying providers across different health plans. They serve as universal identifiers, facilitating seamless, efficient electronic transactions between healthcare entities.
Additionally, the U.S. government assigns health plans participating in electronic healthcare transactions a unique 6-digit number. This is known as the National Plan and Provider Enumeration System (NPPES) enumeration System identifier (ESI). The NPPES ESI enables accurate identification in electronic data interchange.
Employer identification number
The employer identification number (EIN) (assigned by the Internal Revenue Service) is a unique 9-digit number assigned to organizations. When conducting electronic healthcare transactions, employers provide their EIN as part of standard identifier information. EINs enable seamless coordination within the healthcare organization, ultimately benefiting patients by expediting the processing of claims and eligibility verification.
Health plan identifier
The purpose of a standard health plan identifier (HPID) was to uniquely identify a health plan. The government also adopted the other entity identifier (OEID). OEID functioned as voluntary identifiers for entities not labeled as health plans, healthcare providers, or individuals that need to be identified in HIPAA transactions.
Both identifiers were created to identify health plans (or similar) in a uniform way to increase productivity. However, as of December 2019, the Centers for Medicare & Medicaid Services (CMS) rescinded the adoption of HPIDs. Currently, all HPIDs and OEIDs remain deactivated.
Unique patient identifier
The unique patient identifier (UPI) is specifically for patients. UPIs serve as anonymous classifiers to help covered entities share health records with improved proficiency. Like other healthcare identifiers, the number is unique and does not contain PHI.
Currently, there is no HIPAA standard as to what organizations should include in UPIs. This identifier is not universal across all healthcare systems in the U.S. Instead, there is an expectation that healthcare organizations will adopt and use UPIs for patient protection.
Benefits of the HIPAA Unique Identifier Rule
The government created HIPAA, including the Unique Identifier Rule, to aid in the safekeeping of PHI and ensure its responsible use. Given this, there are several benefits:
- A standardized code protects sensitive patient information and minimizes the risk of data breaches.
- HIPAA identifiers recognized universally by healthcare organizations support the safe movement of data between health-related entities.
- Using unique identifiers means better administrative interoperability and effectiveness, further promoting the safe exchange of HIPAA compliant data.
With UIDs, healthcare providers can seamlessly exchange information, improve processes, and reduce burdens. For healthcare organizations, securely managing patients and their PHI can only lead to better patient confidentiality and care.
Challenges in implementation
While the government designed these provisions to enhance efficiency and security, their implementation isn't without challenges. Smaller healthcare practices, for example, struggle with the financial and technical demands of HIPAA compliance. Additionally, healthcare organizations must consider the risk of re-identification linking sensitive information back to individuals.
Balancing healthcare with HIPAA's strict security measures poses many dilemmas for providers.
Kapua Iao
