Under rules related to the HIPAA electronic transaction regulations, employer-sponsored health plans, whether insured or self-funded, are required to acquire from the CMS so-called “Health Plan Identification Numbers” (or “HPIDs”).
For insured plans, the insurance carrier must obtain the HPID, so sponsors of insured plans are not required to do anything at this point.
For self-funded plans the plan sponsor is responsible for obtaining an HPID. This requirement applies to self-funded medical, dental or vision plans. Health FSAs are not required to obtain an HPID. HRAs that are integrated with a health plan and pay only deductible amounts or out-of-pocket amounts that are not covered under that health plan also are not required to obtain an HPID.
Self-funded plans with $5,000,000 or more in annual claims are required to acquire their HPIDs by November 5. (Smaller plans are required to acquire their HPIDs by November 5, 2015.)
Fortunately, the regulators have made it relatively easy for an employer to acquire an HPID without significant assistance from outside service providers (and related costs). However, it does take a few days to complete the process because each step in the application process must be approved by CMS before the employer may move to the next step, and CMS approval takes from a few hours to a few days.
Please let us know if you have any questions about this upcoming filing requirement.