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A Look at the HPID Application Experience
Verrill Dana LLP Link to more items from this source
[Guidance Overview]
Oct. 17, 2014

"Small health plans that report annual receipts of $5 million or less (not to be confused with sub-health plans) will have an additional year to obtain an HPID. HPIDs must be used in all standard transactions beginning November 7, 2016. Self-insured health plans may authorize a third-party administrator to obtain an HPID on its behalf, but the HPID will belong to the health plan and it remains the obligation of the health plan to ensure the HPID is obtained by the deadline."

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