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Health Plan Sponsors: Hurry and Get Your HPID -- or NOT!
Benefits Bryan Cave Link to more items from this source
[Guidance Overview]
May 21, 2014
"A plan sponsor that is inclined to simply apply for an HPID for each of its group health plans should be aware that the HPID may become the identifier for future administrative simplification initiatives. For example, HHS is considering use of the HPID to track CHPs that have satisfied the certification of compliance for health plans (another HIPAA compliance item but for 2015). Hopefully HHS will exempt self-funded health plans that do not engage directly in covered transactions from the certification in response to comments submitted to the proposed regulations published earlier this year. If this turns out not to be the case, a plan sponsor could set itself up for multiple testing and certification requirements if each plan has its own HPID."

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