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News for Self-Funded Employers: HPID Requirement Delayed

Self Funded Employers: Compliance Alert: HPID Requirement DelayedOn Oct. 31, 2014, the Centers for Medicare & Medicaid Services (CMS) announced that enforcement of the Health Plan Identifier (HPID) requirement is delayed until further notice. The initial deadline required self-funded employer group health plans (among other “covered entities”) to obtain an HPID by Nov. 5, 2014.

CMS has not yet indicated if or when there will be a new deadline for obtaining the HPID.

Below is a brief overview of the HPID requirement:

What is the HPID?

  • The Health Plan Identifier (HPID) is a standard, unique health plan identifier required by HIPAA
  • It is intended to replace proprietary health plan identifiers that vary in lengths and formats

Who Does the HPID Requirement Apply To?

  • The HPID requirement applies to group health plans subject to HIPAA’s administrative simplification provisions
  • Health plans that have fewer than 50 participants and are administered by the employer that maintains the plan are not subject to the HPID requirement
  • Fully-insured group health plans are not exempt from the HPID requirements; however, they do not need to obtain a separate HPID, as health insurance issuers (carriers) are required to obtain HPIDs
  • In regards to the HPID, health plans are divided into controlling health plans and sub-health plans.

Additional Information

I hope that you find this information helpful as you seek to assess your company’s potential compliance requirements. Stay tuned to CBG Benefits as additional information is released about the HPID requirement.

If you have any questions in the meantime, please contact our staff at 781-759-1222.

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Posted in: Human Resources, Legislation

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