HPID Requirement

[gregmk]

Has anyone successfully obtained an HPID as required in 45 C.F.R. § 162.512 for a self-insured multiemployer welfare plan? The process seems to involve registering a "company" with HHS. I'm not clear on how a multiemployer plan would do this. Potentially register the board of trustees as the "company"? I'd appreciate any thoughts.

-Greg

[Guest LanceBJohnson]

Hi Greg: I have exactly the same problem. As my multiemployer clients file 5500s certainly the IRS knows who we are. I am not going to offer up my Trustees personally with any additional registration.

At the moment, I am going to wait until the IFEB conference in Boston and ask questions.

Are you going to the annual IFEB?

Lance

[gregmk]

Lance,

I unfortunately can't make the IFEBP conference this year, though I'd be appreciative if you relayed any additional info you do come up with. Since I originally posted my question, I've heard over informal channels that HHS is planning on simplifying the process to accommodate multiemployer plans before the November 15 due date, but that is all I know.

-Greg