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CMS FAQ: Insurer is Required to Obtain HPID for Fully Insured Health Plan

The Centers for Medicare & Medicaid Services (?Ç£CMS?Ç¥) issued a FAQ and quick reference guide outlining the process for a health plan to obtain a health plan identifier (?Ç£HPID?Ç¥). Among its guidance, CMS explains that for fully-insured plans, the insurer is treated as offering a controlling health plan (?Ç£CHP?Ç¥) and thus must obtain the HPID. The individual employer plans are sub health plans (?Ç£SHPs?Ç¥) to the fully-insured CHPs. The SHPs may obtain HPIDs, but are not required to.

The CMS FAQ can be found here. The CMS quick reference guide can be found here.

The lawyers of our Employee Benefits and Executive Compensation Practice Group are readily able to assist companies on a nationwide basis with implementing sophisticated benefit plans and providing answers to their most challenging compensation issues. Additionally, our lawyers are well aware of the daily employee benefits challenges facing companies of all sizes and are capable of helping in-house lawyers and human resources personnel with the day-to-day advice and guidance necessary to properly administer employee benefits plans.

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