The Centers for Medicare & Medicaid Services (?ãCMS?ÃÂ¥) issued a FAQ and quick reference guide outlining the process for a health plan to obtain a health plan identifier (?ãHPID?ÃÂ¥). Among its guidance, CMS explains that for fully-insured plans, the insurer is treated as offering a controlling health plan (?ãCHP?ÃÂ¥) and thus must obtain the HPID. The individual employer plans are sub health plans (?ãSHPs?ÃÂ¥) 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.
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Practical Benefits Lawyer
CMS FAQ: Insurer is Required to Obtain HPID for Fully Insured Health Plan
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