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The Wagner Law Group Description 

The Wagner Law Group, A Professional Corporation, is a nationally recognized ERISA & employee benefits, estate planning, employment, labor & human resources practice. 


Established in 1996, The Wagner Law Group has 22 attorneys engaged exclusively in employee benefits, estate planning and employment law. Six of our attorneys are AV rated by Martindale-Hubbell as having very high to preeminent legal abilities and ethical standards. The firm is among the largest ERISA boutiques in the country. Our practice is national in scope, with clients in more than 40 states and several foreign countries.






Contact Info

The Wagner Law Group


  Integrity | Excellence


Massachusetts Office 

Tel: (617) 357-5200 

Fax: (617) 357-5250 

99 Summer Street 

13th Floor

Boston, MA 02110

Florida Office 

Tel: (561) 293-3590
Fax: (561) 293-3591
7108 Fairway Drive
Suite 125
Palm Beach Gardens, FL 33418


San Francisco Office

Tel: (415) 625-0002

Fax: (415) 358-8300

315 Montgomery Street

Suite 904

San Francisco, CA 94104







November 6, 2014


 Health and Welfare Law Alert





Enforcement of HIPAA's HPID

Requirements Delayed 




The Centers for Medicare & Medicaid Services ("CMS") has announced that enforcement of HIPAA's Health Plan Identifier ("HPID") rules is delayed until further notice. This delay applies to the requirement that health plans obtain an HPID and use it when engaging in HIPAA standard transactions.


Background. The HPID is a standard, unique 10-digit number that will be used to identify a group health plan when it engages in standard transactions. HIPAA requires HHS to establish uniform standards for electronic transactions between group health plans and health care providers such as doctors, pharmacies, and hospitals. In 2012, HHS implemented this mandate by issuing final regulations requiring all group health plans to use an HPID in standard transactions.


Original HPID Deadlines. Large self-funded group health plans were originally required to apply for an HPID by November 5, 2014, while small self-funded group plans (i.e., those with annual claims of $5 million or less) had an additional year to obtain HPIDs. All covered entities were required to begin using HPIDs no later than November 7, 2016, in standard transactions involving health plans that had an identifier.


Delay of HPID Requirements. CMS has indicated that, effective October 31, 2014, there is an indefinite delay in the enforcement of the HPID requirements. This delay applies to all covered entities, including group health plans. CMS has not indicated whether there will be a new deadline for obtaining the HPID, or what that deadline might be.


Action Steps for Plan Sponsors. As a result of CMS's enforcement delay, the sponsor of a group health plan that is subject to the HPID requirements and that has not yet obtained its HPID can postpone doing so until further notice. A health plan sponsor that has already obtained its HPID should maintain a record of its number. For more information on the HPID requirements, including an overview of the application process, see the Alert of 9/4/14. 




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This Newsletter is provided for information purposes by The Wagner Law Group to clients and others who may be interested in the subject matter, and may not be relied upon as specific legal advice.  This material is not to be construed as legal advice or legal opinions on specific facts. Under the Rules of the Supreme Judicial Court of Massachusetts, this material may be considered advertising.