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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







September 4, 2014


 Health and Welfare Law Alert




Health Plan Identifier Application Deadline Approaching for Self-Insured

Group Health Plans




Under final regulations issued by HHS in 2012, all group health plans must apply to the Centers for Medicare & Medicaid Services ("CMS") for a 10-digit health plan identifying number ("HPID"). The HPID will be used to identify a group health plan when it engages in "standard transactions."


Background. 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 issued final regulations to implement this mandate. In particular, the final regulations require all health plans to use an HPID in standard transactions.


Application Deadline. Large self-funded group health plans must 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) have an additional year to obtain their HPIDs. Insurers will apply for HPIDs on behalf of fully insured plans.


HPID Application Process. To obtain a HPID, a health plan's representative must apply through CMS's Health Plan and Other Entity Enumeration System ("HPOES"). To do so, an organization must use the following application process: 

  1. register with the Health Insurance Oversight System ("HIOS") via HPOES;
  2. access the user management role;
  3. select the application type;
  4. complete the application; and
  5. have the application reviewed by the employer's authorizing official.  

Once this process is completed, the system will issue an HPID for the group health plan.


NOTE: An authorizing official is an executive of the plan sponsor who has authority to enter into binding legal agreements on behalf of the plan.


Using the HPID. Group health plans are not required to begin using HPIDs in standard electronic transactions until November 5, 2016. However, group health plan sponsors are advised to begin furnishing their HPIDs to third party administrators and other business associates in advance of this date so that they can begin to incorporate the HPID into their administrative systems and processes.


Group health plan sponsors may use the HPID to identify the group health plan in circumstances other than standard transactions. For example, plan sponsors may incorporate the HPID into the plan's internal records or membership cards, or in material available to health care providers.


The CMS Health Plan Identifier webpage has helpful information, including detailed, step-by-step instructions on how to apply for an HPID. The CMS webpage can be accessed at: http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Health-Plan-Identifier.html





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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.