CMS Clarifies Health Plan ID Requirement for Wrap Plans

The Centers for Medicare and Medicaid Services (CMS) has revised its Health Plan ID (HPID) FAQs to provide clearer guidance for employers who wrap multiple self-funded benefit programs into a single ERISA plan for purposes of the annual Form 5500 filing. In what was previously unclear, the updated guidance confirms that a  plan sponsor may obtain a single HPID for all self-funded “controlling health plans” (CHP) offered through a wrapped ERISA plan.  

The FAQ provides the following example: 

For example, an employer that sponsors a single ERISA plan that includes 10 self-insured major medical options, an HMO, two self-insured dental plans, and a fully-insured vision plan has the option to obtain just one HPID for the entire plan. (HPIDs for fully-insured benefits or arrangements within the ERISA plan generally will be obtained by the carrier.)

The guidance also states that employers may obtain a separate HPID for each self-funded CHP in the wrap plan.  Under this approach, the employer would individually analyze each self-funded benefit program to determine whether it would qualify as a CHP if it were offered through a stand-alone plan.  The employer would then apply for a separate HPID for each benefit program that meets the definition of CHP.  

While this clarification may be good news for many employers, remember that CHPs that do not qualify for the “small controlling health plan” exception are required to obtain HPIDs no later than November 5, 2014.

Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.