New FAQ Approves Use of One HPID Per ERISA Plan

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New FAQ Approves Use of One HPID Per ERISA Plan
Calendar28 October 2014

Employers’ receipt of a single federal health plan identifier (HPID) number to cover all self-insured health components within the same ERISA plan has been approved by the Department of Health and Human Services in a new “frequently asked question” (FAQ10848). The guidance confirms that a sponsor may choose to obtain just one HPID for each ERISA plan. Employers not subject to ERISA, like state and local governments, can use the same single-HPID approach if they sponsor “wrap” plans or similar multiple-benefit arrangements treated as a single plan. In prior guidance, the Department said self-insured plans no longer need to involve an "authorizing official" in the application process. A related system upgrade now allows applicants to request HPIDs without sign-off from a registered authorizing official.

Reporting health plan enrollment data for the 2014 transitional reinsurance fee can now begin using the online form made available October 24 on www.pay.gov. Employers with self-insured health plans must register on that site and use the form to submit enrollment counts and schedule fee payments. Although forms are normally due November 15, agency staff stated during a recent Q&A session that the deadline to submit 2014 forms is November 17, since the 15th falls on a Saturday this year. Additional Q&A sessions are scheduled through November 17; participation is available via registration on the REGTAP website. 

The Administration has opened a new health insurance portal to small businesses (fewer than 50 full time workers) in five states after a year-long delay of the ACA’s Small Business Health Options Program (SHOP) online marketplace for these employer plans. An “early access” version of the program launched over the weekend in Delaware, Illinois, Missouri, New Jersey and Ohio. The limited launch is a warm-up before the small business exchange rolls out for most of the rest of the country on November 15. 

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