CMS HPID Guidance Just in Time – Updated
The deadline for large health plans (receipts over $5 million) to obtain the new health plan identifier (HPID) is November 5, 2014. For insured health plans, the insurance carrier is responsible to obtain HPID, but for self-insured plans, that responsibility falls on the plan sponsor. But, until now employers have had a difficult time navigating through the process of obtaining an HPID. See the ERISA Industry Committee Survey.
CMS has recently published some helpful guidance on obtaining an HPID. First, CMS published a Quick Reference Guide. The Guide includes step-by-step procedures for obtaining the HPID by using the CMS Enterprise Portal to access the CMS Health Insurance Oversight System (HIOS). Second, HMS published a set of helpful FAQs about HPIDs
In addition to this guidance, CMS has corrected some glitches in the application process. For example, at one time CMS would only recognize one controlling health plan for each EIN. CMS now says that they have corrected the system so that it will issue HPIDs to multiple health plans that register under a single EIN. CMS has also eliminated the requirement to obtain an NAIC number or Payer Identification Number in order to proceed with obtaining an HPID. A self-insured plan can now enter “not applicable” in response to any request for those numbers.
The HPID rules require that every “controlling health plan” must obtain an HPID, but each “subhealth plan” is given the option to obtain its own HPID or use the HPID of the controlling health plan. While the CMS guidance and other fixes to the application process are very helpful, employers could use more information on the definition of those terms in the context of self-insured employer plans. Unfortunately, that information may not come in time for employers to meet the November 5 deadline.
Update: HHS has again streamlined the HPID process by eliminating the requirement for an executive of the plan sponsor to approve HPID application. An updated Quick Reference Guide is available here. For those wanting a more detailed information, HHS also recently published a Health Plan and Other Entity Enumeration System User Manual.