HIPAA, HRAs & HSAs

Benefits News Flash! HPID Delayed Indefinitely, & HFSA Pre-tax Amount Increased to $2550

1- HPID Delayed Indefinitely

As a Halloween treat, on October 31, 2014 the federal government indefinitely delayed enforcement of the Health Plan ID requirements. This means that large self-insured group health plans do NOT have to obtain an HPID by November 5, 2014.   I guess the Halloween treat was also a trick for those large group plans that have already spent time applying for the HPID.

The official statement from CMS/HHS is reproduced below (after the HFSA information) and is at:http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Health-Plan-Identifier.html

2- Health FSA Pre-Tax Amount Increased to $2550 for 2015

The IRS has increased the maximum annual employee pre-tax contribution to Health FSA accounts to $2550 for 2015 (a $50 increase from $2500 in 2014). HFSAs are governed by IRC section 125.

Most HFSA plan documents that have been amended to limit the annual salary reduction contribution to $2500 probably also say that the annual maximum amount will automatically be increased each year to the annual indexed amount, but it would a good idea to check your HFSA plan documents/amendments to make sure.  If  you have not yetformally  adopted this amendment, you have until December 31, 2014 to do so.  The annual limits apply whether or not a plan has been formally amended.

 

Below is the official Statement on the HPID Delay:

Statement of Enforcement Discretion regarding 45 CFR 162 Subpart E – Standard Unique Health Identifier for Health Plans

Effective October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) Office of e-Health Standards and Services (OESS), the division of the Department of Health & Human Services (HHS) that is responsible for enforcement of compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) standard transactions, code sets, unique identifiers and operating rules, announces a delay, until further notice, in enforcement of 45 CFR 162, Subpart E, the regulations pertaining to health plan enumeration and use of the Health Plan Identifier (HPID) in HIPAA transactions adopted in the HPID final rule (CMS-0040-F).

This enforcement delay applies to all HIPAA covered entities, including healthcare providers, health plans, and healthcare clearinghouses.

On September 23, 2014, the National Committee on Vital and Health Statistics (NCVHS), an advisory body to HHS, recommended that HHS rectify in rulemaking that all covered entities (health plans, healthcare providers and clearinghouses, and their business associates) not use the HPID in the HIPAA transactions (see http://ncvhs.us/wp-content/uploads/2014/10/140923lt5.pdf). This enforcement discretion will allow HHS to review the NCVHS’s recommendation and consider any appropriate next steps.