Health Plan Identifiers Guidance for BPC Plans

UPDATE: We would like to pass along news of an indefinite enforcement delay related to obtaining and using a unique Health Plan Identifier (HPID).  BPC had previously informed clients that some of their health plans might need to obtain an ID by November 5, 2014, with a deadline of a year later for smaller plans.  According to a statement released late on Friday, October 31, the Centers for Medicare and Medicaid have announced a suspension of all enforcement surrounding HPIDs.  Until further notice, no action needs to be taken with regard to obtaining or using an HPID for any of your health plans.  The full statement can be viewed here.


The Centers for Medicare & Medicaid Services (CMS) released a set of Frequently Asked Questions addressing many of the outstanding questions surrounding the Health and Human Services' 2012 mandated Health Plan Identifiers (HPIDs) for Controlled Group Health Plans.

A Controlled Health Plan (CHP) is a health plan that controls its own business activities, actions, or policies, or is controlled by an entity that is not a health plan. A health plan is also a CHP if it has one or more sub health plans (SHPs) that it controls by directing the SHP's business activities, actions, or policies.

Until recently, confusion around which health plans needed to obtain the HPID was widespread, even as the November 5, 2014 deadline has been rapidly approaching. The result was mostly good news for account-based plans.  According to the FAQs:

  • Flexible Spending Accounts (FSA) and Health Savings Accounts (HSA) do not require an HPID.
  • Health Reimbursement Arrangements (HRA) will not require an HPID if the HRA covers only "deductibles or out-of-pocket costs". For example, if an HRA can only reimburse expenses the group health plan classifies as cost-sharing amounts such as deductible, copayments, and coinsurance, it does not need to obtain an HPID. On the other hand, if the HRA can reimburse expenses that are not covered at all by the major medical plan, such as over-the-counter medical supplies or acupuncture, it generally will need to obtain its own HPID.

Next Steps: For many plans, including the few HRA's that require an HPID, the deadline to obtain the number is still over a year away. As confirmed in the FAQs, small plans have until November 5, 2015 to obtain the number. A small plan is defined as one with annual receipts of $5 million or less, a threshold which few HRA's will reach. 

To the extent that your other group health plans are considered Controlling Health Plans, you may need to obtain one or more HPID's by November 5, 2014or November 5, 2015. For fully insured plans, the HPID should be obtained by the insurance carrier. Employers sponsoring self-funded plans may need to obtain the HPID themselves, or coordinate with the third-party administrator of the plan to obtain the HPID. BPC recommends contacting your insurance carriers or plan administrators with any questions you have about those plans.

To read the full text of the CMS FAQs, click here.

Posted on November 1, 2014 .