by Bret Busacker and Bret Clark
Now that fall is in the air and school has started, we thought it would be a good idea to summarize some of the key health and welfare benefit deadlines that are approaching. 
November 5
Health plan identifier. All self-insured large group health plans (i.e., plans with annual costs of $5 million or more) must obtain a unique group health plan identification number (HPID) from the Centers for Medicare & Medicaid Services by November 5, 2014. HPIDs are used in electronic communications involving plan-related health information. For that reason, third-party administrators of self-insured plans must obtain an HPID or work with the plan sponsor to obtain an HPID.
Confirm with your third-party administrator that your plan will have an HPID by the deadline. Please note that you should obtain an HPID for each group health plan you maintain. Accordingly, if you have a single wrap-around group health plan that encompasses all of your group health plans, you may need to obtain only one HPID. However, employers that maintain separate health reimbursement accounts, FSAs, or medical, dental, or vision plans may be required to obtain an HPID for each plan. Small group health plans have until November 5, 2015, to obtain an HPID. To learn more, visit www.cms.gov/regulations-and-guidance/hipaa-administrative-simplification/affordable-care-act/health-plan-identifier.html.
November 15
Transitional reinsurance fee enrollment information. Self-insured health plans must submit their enrollment information to the U.S. Department of Health and Human Services (HHS) by November 15, 2014, for purposes of calculating the 2014 transitional reinsurance fee. Self-insured health plans that are self-administered are exempt from the fee in 2015 and 2016, but they must pay the fee for 2014. Based on enrollment information provided to the HHS in 2014, self-insured plans will pay the fee beginning in January 2015.
General fall planning
ACA shared responsibility planning. The Affordable Care Act’s (ACA) shared responsibility penalties will begin to be imposed on employers with 100 or more full-time or full-time-equivalent employees on January 1, 2015. Start determining whether you will be subject to the employer shared responsibility penalties and, to avoid those penalties, whether you cover full-time employees who must be offered coverage.
Summary of benefits and coverage, Women’s Health and Cancer Rights Act notice, Medicaid/CHIP premium assistance notice, HIPAA notice of privacy practices, and exchange notice. Confirm that these notices are included in the enrollment materials provided to participants during open enrollment and to participants who are newly eligible for your plan. If the notices are not included in the enrollment materials prepared by your provider, consider supplementing the materials with the notices. Also, confirm that your COBRA notices have been updated to reflect recent changes to the model COBRA notice regarding the establishment of the health insurance exchanges.
Bottom line
As health and welfare benefit plans become a higher priority for the IRS and the U.S. Department of Labor (DOL), 
it becomes more and more important for employers to stay on top of compliance issues. 
Compliance with the deadlines will get you on the right path for 2015.
Bret Busacker is an attorney with Holland & Hart. He may be contacted at bfbusacker@hollandhart.com.
Bret Clark is an attorney with Holland & Hart. He may be contacted at sbclark@hollandhart.com.