The Centers for Medicare and Medicaid Services (CMS) has revised its Health Plan ID (HPID) FAQs to provide clearer guidance for employers who wrap multiple self-funded benefit programs into a single ERISA plan for purposes of the annual Form 5500 filing. In what was previously unclear, the updated guidance confirms that a plan sponsor may obtain a single HPID for all self-funded “controlling health plans” (CHP) offered through a wrapped ERISA plan.
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