"If a plan is fully insured, the insurer will apply for the HPID. But if the plan has a self-funded component (e.g., prescription drug coverage), the plan will need an HPID. In determining if a plan has a self-funded component for this purpose, generally the flexible spending accounts and retiree health reimbursement accounts can be disregarded.... For employers with wrap plans that file a single Form 5500, it may be easier to obtain a single HPID for the entire plan, including all of the self-insured programs or 'subhealth plans' -- even if there are fully insured programs within the wrap plan[.]"  MORE >>