The Centers for Medicare & Medicaid Services (“CMS”) issued a FAQ and quick reference guide outlining the process for a health plan to obtain a health plan identifier (“HPID”). Among its guidance, CMS explains that for fully-insured plans, the insurer is treated as offering a controlling health plan (“CHP”) and thus must obtain the HPID. The individual employer plans are sub health plans (“SHPs”) to the fully-insured CHPs. The SHPs may obtain HPIDs, but are not required to.

The CMS FAQ can be found here. The CMS quick reference guide can be found here.