CMS Announces Last-Minute Enforcement Delay For HPID Requirement

Sponsors of large, self-funded health plans struggling with the new Health Plan ID (HPID) requirement received a last-minute reprieve from the Centers for Medicare & Medicaid Services (CMS).  On Friday, the CMS announced an enforcement "delay" with respect to the health plan enumeration and HPID regulations.  The announcement comes on the heels of clarifying guidance from the CMS explaining how the HPID application process affects ERISA "wrap" plans. 

CMS does not explain why it chose to exercise its enforcement discretion so close to the November 5, 2014 deadline for obtaining HPID, nor does it explain how long the delay will remain in place.  Instead, the announcement states the enforcement delay will be in effect "until further notice."