"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..."
They also state:
"Can a health plan authorize a person to get a Health Plan Identifier (HPID) for the health plan?
Yes. An authorized person is permitted to enroll the health plan in the Health Plan and Other Entity Enumeration System (HPOES)."
The FAQs are available here.

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