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October 2, 2014

Guidance on Required Health Plan Identifiers

On October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) announced that it was delaying, until further notice, enforcement of the regulations requiring health plans to obtain a Health Plan Identifier (HPID), and for HIPAA covered entities, including health plans and health care providers, to use HPIDs. The agency’s statement is on the CMS website.

In September 2014, the Centers for Medicare & Medicaid Services (CMS) published answers to frequently asked questions (FAQs) relating to health plan identifiers (HPIDs)* that provide the following guidance:

  • Health insurance issuers must obtain the HPID for fully insured plans. Plan sponsors with a fully insured plan option do not have to obtain the HPID for that plan. (See FAQ 10716.)
  • Health Flexible Spending Arrangements (FSAs) and Health Savings Accounts (HSAs) do not require HPIDs because they are consumer-directed individual accounts. (See FAQ 10718.)
  • Health Reimbursement Arrangements (HRAs) are not required to obtain an HPID if the HRA covers deductibles only or out-of-pocket costs. (See FAQ 10718.)
  • If a plan sponsor has benefits in addition to a fully insured medical plan (sometimes called a wrap plan), each plan is considered separately. For example, an employer may have a fully insured medical plan, a self-insured dental plan, and an HRA (covering deductibles). In this example, the insurer would be responsible for the HPID for the fully insured medical plan and the employer would obtain the HPID for the self-insured dental plan. The HRA would not need an HPID because it covers only deductibles. (See FAQ 10718.)
  • A health plan may authorize another party (such as a TPA) to get an HPID for it. (See FAQs 10698 & 10712.)
  • To determine whether a self-insured plan is a small health plan (annual receipts of $5 million or less), use the total amount paid for health care claims by the employer, plan sponsor, or benefit fund, as applicable, on behalf of the plan during the plan’s last full fiscal year. (See FAQ 10702.)

These FAQs can be found by typing “HPID” or a particular FAQ number into the search boxes found at

CMS also issued a “Quick Reference Guide to Obtaining a Controlling Health Plan HPID.”

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As with all issues involving the interpretation or application of laws, health plan sponsors should rely on their legal counsel for authoritative advice on HPIDs. As details of the process become clearer, Sibson Consulting will communicate the news. Sibson can be retained to work with plan sponsors and their attorneys on compliance issues related to HPIDs.


* Most self-insured group health plans, except for small ones, must obtain a new 10-digit health plan identifier (HPID) by November 5, 2014. For more information about this requirement, see Sibson’s July 25, 2014 Capital Checkup. (Return to the Capital Checkup.)


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