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HPID Deadline is November 5
Sutherland Asbill & Brennan LLP Link to more items from this source
[Guidance Overview]
Oct. 30, 2014
"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[.]"

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