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Enforcement Delayed for Health Plan Identifier Regulations: The Department of Health and Human Services (HHS) announced on October 31, 2014, that it will delay enforcement of regulations related to obtaining the Health Plan Identifier (HPID) and using the HPID in Health Insurance Portability & Accountability Act (HIPAA) transactions that were adopted in the HPID final rule. It applies to all HIPAA covered entities, including healthcare providers, fully insured and self-funded health plans, and healthcare clearinghouses. Insured plans and self-funded health plans that have not already obtained an HPID do not need to do so until further notice. This delay comes on the heels of a recommendation by the National Committee on Vital and Health Statistics (NCVHS), an advisory body to HHS. The NCVHS asked HHS to review the HPID requirement and recommended that HPIDs not be used in HIPAA transactions. NCVHS’s primary opposing argument to implementation of the HPID standard was that the healthcare industry has already adopted a “standardized national payer identifier based on the National Association of Insurance Commissioners (NAIC) identifier.”

Other Reasons for the Change: Lack of clear business need and purpose for the HPID • Confusion about how the HPID would be used in administrative transactions • Challenges faced by health plans defining controlling health plan (CHP) and sub health plan (SHP) • Cost to health plans, clearinghouses, and providers if software has to be modified to account for the HPID. Whether HHS will adopt the recommendations of the NCVHS on a permanent basis remains to be seen, but for the time being, plan administrators may discontinue the HPID application process and should stay tuned for further announcements from HHS.

IRS Increases 2015 Health FSA Contribution Limit: For taxable years beginning in 2015, the dollar limitation under §125(i) on voluntary employee salary reductions to health flexible spending arrangements is $2,550, up from the 2014 limit of $2,500 (IRS Revenue Procedure 2014-61).