Required Compliance Items for Self-Funded Plans – November deadline
HPID: Self-funded plans must obtain an HPID by November 5, 2014. Health reimbursement accounts (HRA) and MERPs with 50 or more participants are considered self-funded plans under HIPAA and will need to obtain an HPID even if they have a fully insured group health plan. However, HRAs that cover only deductibles or out-of-pocket costs do NOT require HPIDs.
NOTE: Self-funded plans with annual receipts of $5 million or less will have until November 5, 2015 to get an HPID.
Transitional Reinsurance Fee: The Transitional Reinsurance Fee, established under
PPACA, requires self-funded medical plans to send HHS head count information based on
the first three quarters of the calendar year no later than November 15, 2014. The fee
for 2014 is set at $63 per health care plan participant per year.