HPID: Is it possible that a plan never uses its HPID?

[Peter Gulia]

Much has been written about a requirement that a non-insured group health plan obtain a health plan identifier [HPID].

But if the only thing the plan does is pay or deny a claim submitted by a participant, when (if ever) does such a plan use this new identifier?

[Peter Gulia]

To be clear, I'm asking about a situation in which the plan has no need to communicate with anyone beyond the participant who submitted a claim.

A part of why I'm asking is that a client asked how the U.S government would detect that the plan lacks the identifier? The same employer asked what liability or penalty could result from failing to use or obtain the identifier?

[Bill Presson]

I'll be very interested to see if anyone else has thoughts on this as well.

[Peter Gulia]

Now that the government has delayed enforcement, it might be a while before anyone figures out an answer to my query.