October 8, 2014

HPID Compliance Assistance Tools (article)

Two prior Benefit Beat articles this summer provided information relating to the requirements of certain plans to obtain a health plan identifier (HPID).  In a nutshell, the HIPAA electronic transaction rules require plans to obtain an HPID for purposes of streamlining claim payments.  In addition, the Affordable Care Act requires “controlling health plans” (CHP) and “subhealth health plans” (SHP) with an HPID to certify compliance with certain electronic transaction standards. 


Large CHPs are required to obtain an HPID by November 5, 2014; by November 5, 2015 for small CHPs (those with “annual receipts” of $5 million or less).  


To assist plan sponsors in this process, the Centers for Medicare and Medicaid Services have recently issued a flow chart of the HPID process (in both a graph and text format) together with some Questions and Answers, and revised their technical manual.  


The Q&As clarify a number of matters, as follows:

  • The insurer is obligated to obtain the HPID on behalf of an insured plan. 
  • An employer/plan sponsor of a self-funded plan is obligated to obtain the HPID on behalf of its self-funded plan. 
  • An employer requesting an HPID on behalf of self-funded plan would not be required to provide the plan’s NAIC number.  This entry on the application would be marked ‘not applicable’.
  • An HPID is not required for a flexible medical spending account plan or a health savings account. 
  • While an HPID is generally required to be obtained by a health reimbursement arrangement (HRA), there are certain exceptions.  An HRA that only reimburses the deductibles and out-of-pocket expenses of the corresponding comprehensive health plan would not be required to obtain an HPID.  While not fully clear from the Q&As, it appears that if an employer has wrapped multiple health components into one plan, an HPID would not have to be obtained for the HRA that is included in this combined package.

While there have been rumors that the HPID requirement would be delayed or repealed, thus far, it has not happened.  And given that the process is somewhat convoluted, large self-funded plans will want to consider commencing the application for the HPID sooner than later. 


Additional information about obtaining an HPID can be found on the CMS website.


Background Benefit Beat articles:


The information contained in this article is provided as general guidance and may be affected by changes in law or regulation. This article is not intended to replace or substitute for accounting or other professional advice. Please consult a CBIZ professional. This information is provided as-is with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein.