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CMS Delaying Enforcement of Regulations Related to Unique Health Plan Identifiers

Publications - Client Alert | November 3, 2014

Late Friday afternoon (October 31, 2014), the Center for Medicare & Medicaid Services (CMS) announced it will not be enforcing the regulations relating to unique health plan identifiers (HPIDs) until further notice. The enforcement delay applies to all HIPAA-covered entities, including health plans.

As background, prior to the CMS’ announcement, large health plans (those with annual receipts exceeding $5 million) were required to obtain a HPID no later than November 5, 2014, while small health plans (those with annual receipts of $5 million or less) were required to obtain a HPID no later than November 5, 2015.

If you have already obtained a HPID, we suggest retaining records relating to it. If you have not yet obtained a HPID, the CMS announcement delays until further notice the requirement to obtain a HPID.