On Sept. 25, 2014, CMS published “A Quick Reference Guide to Obtaining a Controlling Health Plan HPID.” The quick reference guide is a step-by-by-step outline of how a controlling health plan (CHP) can obtain a health plan identifier (HPID). As background, CHPs (defined as group health plans that control their own business activities, actions and policies) are required to obtain an HPID by Nov. 5, 2014. Smaller CHPs have an additional year to obtain an HPID (by Nov. 5, 2015). HPIDs are obtained via a multi-step process using the CMS website and systems. The reference guide describes those steps and includes screenshots to assist.
In conjunction with the quick reference guide, CMS also published several FAQs relating to the HPID requirement. The FAQs clarify that the carrier is the entity responsible for obtaining an HPID in the fully insured context. For self-insured plans, the employer as plan sponsor is generally responsible for obtaining an HPID. TPAs, even those that administer self-insured plans, are not required to obtain an HPID on behalf of a self-insured plan. Such plans may contract with a TPA to obtain an HPID on their behalf, but the HPID would belong to the plan, not the TPA.
Importantly, the FAQs also clarify how the HPID requirement applies to health FSAs, HRAs and HSAs. The FAQs state that FSAs and HSAs are individual accounts directed by the consumer to pay health care costs, and therefore are not required to obtain an HPID. Note that the underlying HDHP, though, would likely be considered a CHP, and would be required to obtain an HPID. HRAs may require an HPID if they meet the definition of CHP. However, most HRAs will be structured to pay deductibles and other costs associated with the underlying major group medical plan, and therefore would not be a CHP. Such an HRA would instead rely on the group plan’s HPID.
According to the FAQs, where an employer sponsors several benefit package options, but the options are bundled together via a wrap document, the employer may obtain one HPID for the bundled plan rather than multiple HPIDs for each benefit package option. For example, with a wrap plan that includes a fully insured medical plan, self-insured dental plan, and an HRA that covers deductibles, the employer would obtain an HPID only for the self-insured dental plan. Since the HRA covers only deductibles, the HRA would not be required to obtain an HPID-the HRA would rely on the HPID of the fully insured medical plan (obtained by the carrier).
CMS also published a user manual and web page relating to the HPID requirement. The user manual is a detailed description of the Health Insurance Oversight System-the system used by CMS for assigning HPIDs and related identification numbers. The web page includes general information on the HPID requirement, as well as links to other helpful resources that CMS previously made available.