Compliance Alert: HPID Requirements Delayed

The ACA and HIPAA require that self-funded health plans obtain a 10-digit health plan identifier (“HPID”) by November 5, 2014 for large health plans (more than $5 million in annual claim receipts) or November 5, 2015 for small plans ($5 million or less in annual claim receipts), to be used in certain transactions. A carrier will obtain an HPID on behalf of insured health plans.

Effective October 31, 2014, CMS announced an indefinite delay, until further notice, in enforcement of the HPID requirement. This delay was as a result of an advisory board’s recent recommendation¹ that HHS clarify usage of the HPID in certain transactions and the process by which covered entities will certify their use of the HPID to federal regulators.

What Do I Do Now?
Employers who have already obtained an HPID do not need to take any action as a result of this indefinite delay. Employers that are in the process of obtaining the HPID or have not yet begun the application should wait until further guidance is issued before completing or beginning their applications, as appropriate.

The USI National Compliance Team is actively monitoring these regulatory developments and will provide you with additional information as it becomes available.

For more information, see: http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Health-Plan-Identifier.html.

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¹ http://ncvhs.us/wp-content/uploads/2014/10/140923lt5.pdf

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Disclaimer: This document is designed to highlight various employee benefit matters of general interest to our readers. It is not intended to interpret laws, regulations or to address specific client situations. It should not be construed as legal advice or opinion.

USI is a leading provider of employee benefit programs, commercial insurance, and retirement plan services operating nationally with 140 offices. In today’s climate of escalating health care costs, USI has the knowledge and resources to support your company’s critical employee benefits decisions. We offer strategic cost containment solutions, integrated wellness programs, compliance services, and administration and communication services. Please contact your USI representative for additional information.

Copyright © 2014 USI Insurance Services. All Rights Reserved.

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