Employee Benefits-Certain Health Plans Face November 5 and 15 Deadlines

A reminder: any health plan, which is self-insured and constitutes a “large health plan”, must obtain a health plan identifier number (a “HPID”) by November 5, 2014. The HPID is obtained by registering online with the Centers for Medicare & Medicaid Services’ Health Insurance Oversight System. A “large health plan” is one which paid at least $5 million in claims during its most recently ended fiscal year. It may take a few days to complete the registration, so an affected health plan should start immediately. A self-insured health plan which is not a large health plan has until November 5, 2015 to obtain the HPID.

Another reminder: any health plan, which is self-insured and provides major medical coverage, must furnish the Department of Health and Human Services with a participant count by November 15, 2014. This count is provided in connection with the plan’s Transitional Reinsurance Fee, and is submitted online at www.pay.gov. The transitional reinsurance fee is $63/covered life. The fee for 2014 (or the first installment thereof, if the fund chooses to pay in two installments) is due by January 15, 2015. The fee will not be due for 2015 or 2016, provided that the plan is “self-administered”.