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Smart Benefits: Deadline Next Week for Health Plan Identifiers

Monday, October 27, 2014

 

By November 5, large health plans must obtain a unique national health plan identifier number (HPID), which will be required in certain transactions subject to HIPAA by November 7, 2016.

Large plans are considered those with more than $5 million in annual receipts. Since health plans don’t have receipts, the Department of Health and Human Services says insured plans should look at premiums for the prior plan year and self-funded plans should look at claims paid for the prior plan year.

Small health plans with less than $5 million in claims during the prior plan year have until November 5, 2015, to obtain an HPID.

Who is Exempt?

Health savings accounts (HSAs) and health flexible spending accounts (FSAs) do not require an HPID because they are individual accounts directed by the consumer to pay health care costs. HRAs may require an HPID if they meet the definition of health plan. HRAs that cover deductibles only or out-of-pocket costs do not require HPIDs as these are more like additional plan benefits than stand-alone plans.

HPIDs are also not required for other benefits that are not considered a group health plan, such as life, disability, or a health savings account (although the related high deductible health plan will need an HPID).

Who Obtains the Number?

The insurer carrier obtains the identifier number for fully insured plans. Self-funded plans, on the other hand, need to obtain the number, even if they use a third party administrator (TPA) to pay claims.

How do employers get an HPID?

An employer can apply for its HPID through the Centers for Medicare and Medicaid Services (CMS) website. Many employers will first need to create an account in the CMS Enterprise Portal to obtain a user ID and password.  

Amy Gallagher has over 21 years of healthcare industry experience guiding employers and employees. As Vice President at Cornerstone Group, she advises large employers on all aspects of healthcare reform, benefit solutions, cost-containment strategies and results-driven wellness programs. Amy speaks regularly on a variety of healthcare-related topics, and is often quoted by national publications on the subject matter. Locally, Amy is a member of SHRM-RI, the Rhode Island Business Group on Health, and the Rhode Island Business Healthcare Advisory Council.

 

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