Are Flexible Spending Accounts (FSAs), Health Reimbursement Arrangements (HRAs), Health Savings Account (HSAs), wrap-plans, or cafeteria plans required to get HPIDs?
FSAs and HSAs are individual accounts directed by the consumer to pay health care costs. As such, they do not require an HPID.
HRAs may require an HPID if they meet the definition of health plan. HRAs that cover deductibles only or out-of-pocket costs do not require HPIDs as these are more like additional plan benefits than stand-alone plans.
Wrap-plans and cafeteria plans can be composed of combinations of health plan arrangements (i.e., self-insured, fully-insured, FSA, HAS, HRA). The rules governing these types of plans are the same as for the individual plan types.
For example, a wrap-plan that includes a fully-insured medical plan, self-insured dental plan, and HRA that covers deductibles, would require the employer to obtain an HPID only for the self-insured dental plan. The carrier would be responsible for obtaining the HPID for the fully-insured medical plan. The HRA only covers deductibles; therefore, an HPID is not required.
Source: https://questions.cms.gov/faq.php?id=5005&faqId=10718
