On Friday, Oct. 31, Centers for Medicare and Medicaid Services (CMS) announced that it is exercising the agency’s “enforcement discretion” to “delay, until further notice” enforcement of the Health Plan Identifier (HPID) requirements. For large health plans (those with annual receipts in excess of $5 million), including self-insured health plans sponsored by employers, the deadline to obtain an HPID is scheduled for Wednesday of this week – November 5, 2014.
Presumably, at some point in the future, the enforcement delay will be lifted and there will be a consequence for not having obtained the HPID(s). For employers that have already obtained the HPID(s), they should be in good shape. For employers that have not already obtained the HPID(s), they certainly can still go through the process now. Or, they can wait until later, keeping a close eye on the enforcement position of the CMS.