What is the requirement?
By November 5, 2014, many sponsors of self-funded health plans must apply for and obtain a unique Health Plan Identifier number (HPID) from the US Department of Health and Human Services (HHS).
Whose idea and why?
For more than a decade, the federal government has been moving health plan insurers, group health plans, and health care providers toward standardized electronic formats for common health care transactions. As part of the Affordable Care Act’s reforms, HHS was directed to develop a process for implementing a national health plan identifier system to facilitate electronic transactions.
Who is responsible?
Insurers are responsible for obtaining the HPID for insured plans. Plan sponsors of self-funded plans are responsible for obtaining the HPID for their self-funded plans, even though many employers engage third party business associates to handle electronic transactions for their health plans. Employers must register on an HHS website and input specific plan sponsor and plan data. HHS will then generate the HPID and provide that number to the applicant.
Which self-funded plans must obtain an HPID?
A plan sponsor must obtain an HPID for its large “Controlling Health Plan” by November 5, 2014. In general, we believe that many employers will obtain a HPID for each consolidated health and welfare plan for which it files an annual report (Form 5500), if that health and welfare plan includes a self-funded health plan (medical, including carved-out prescription drug or mental health benefits; dental; or vision) which has paid claims of $5 million or more in the prior year. Sponsors of “small” self-funded plans with less than $5 million in claims have until November 2015 to obtain an HPID.
So an employer’s first step is to determine whether to obtain an HPID for a particular group health plan. Second, they need to register with HHS, and third, they must apply for the identifier number.
Heard about problems with the website?
Earlier this year, employers encountered difficulties using the HHS system for generating HPIDs. HHS recently indicated that certain system problems have been addressed and that self-funded plan sponsors may now obtain an HPID.
Need more information?
An HHS website provides help with the application process including a HPID user manual and a quick guide.