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ARTICLE · 29 OCTOBER 2014

CMS Clarifies Health Plan ID Requirement For Wrap Plans

CMS has revised its Health Plan ID FAQs to provide clearer guidance for employers who wrap multiple self-funded benefit programs into a single ERISA plan.

United StatesEmployment and HR

The Centers for Medicare and Medicaid Services (CMS) has revised its Health Plan ID (HPID) FAQs to provide clearer guidance for employers who wrap multiple self-funded benefit programs into a single ERISA plan for purposes of the annual Form 5500 filing. In what was previously unclear, the updated guidance confirms that a  plan sponsor may obtain a single HPID for all self-funded "controlling health plans" (CHP) offered through a wrapped ERISA plan.  

The FAQ provides the following example: 

For example, an employer that sponsors a single ERISA plan that includes 10 self-insured major medical options, an HMO, two self-insured dental plans, and a fully-insured vision plan has the option to obtain just one HPID for the entire plan. (HPIDs for fully-insured benefits or arrangements within the ERISA plan generally will be obtained by the carrier.)

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