From the Hotline: HRA and HPID
Question: If a self-funded plan has a Health Reimbursement Account (HRA) attached, does the HRA need its own Health Plan Identifier (HPID)?
Answer: On October 31, 2014, the Center for Medicare & Medicaid Services (CMS), the federal agency responsible for enforcement, announced that the Health Plan Identifier (HPID) requirement is delayed until further notice. Plans are not required to obtain HPIDs.
Note that even if CMS had not delayed this item, an integrated Health Reimbursement Account (HRA) would not have needed an HPID. In prior guidance, CMS had confirmed that no HPID was needed if the HRA was merely a component of another health plan (either insured or self-funded).