Late on October 31, the Centers for Medicare and Medicaid Services (CMS) Office of E-Health Standards and Services announced that it was suspending the program that required all health plans to register for a health plan ID number to be used in certain electronic transactions. This program required larger health plans to obtain a health plan ID number by November 5, 2014, and smaller health plans to register for the program by November 5 of next year. The suspension of the program will remain in effect until further notice and is intended to allow for a review of the program altogether. The announcement casts doubt on whether the Health Plan ID program will ever be implemented.

Although the announcement of the suspension is welcome, it will frustrate many employers who in the past several weeks grudgingly undertook the registration process in view of the looming deadline and CMS’s recent issuance of further guidance on the registration process.

If you have questions about health plan ID requirements or other end-of-year health plan considerations, please contact Brian M. Pinheiro at 215.864.8511 or pinheiro@ballardspahr.com, Jean C. Hemphill at 215.864.8539 or hemphill@ballardspahr.com, Diane A. Thompson at 424.204.4334 or thompsonda@ballardspahr.com, Edward I. Leeds at 215.864.8419 or leeds@ballardspahr.com, or any other member of the Employee Benefits and Executive Compensation or Health Care Groups with whom you work.


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