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HHS Proposes to Rescind Health Plan Identifier (HPID) Requirement

Dec 19, 2018 blog featured image

On Dec. 19, 2018, the Department of Health and Human Services (HHS) issued a proposed rule to rescind the HPID and requirements for its use. Under HIPAA, HHS is required to adopt standards for certain electronic transactions. One of the standards is a unique identifier for health plans—the HPID.

In 2012, HHS released a final rule that included deadlines for health plans to obtain their own identifiers and start using them in HIPAA transactions. However, based on industry feedback, HHS indefinitely delayed the HPID requirement before the final rule’s deadlines. HHS has now proposed to rescind the HPID requirement because it has concluded that the HPID does not serve a valid purpose.


It is likely that the proposed rule will be finalized and the HPID will be rescinded. This means that health plans will not be required to obtain an HPID and health care payers may continue to use other identifiers in HIPAA transactions. It is possible that HHS will adopt a more effective HPID standard in the future.


The HPID is a standard, unique health plan identifier that is primarily for use in HIPAA standard transactions. The HPID is intended to address any industry confusion of having multiple ways to identify a health plan in a transaction.

HHS released a final rule adopting the HPID standard on Sept. 5, 2012. The final rule would have required most self-insured health plans to obtain their own HPID. For insured plans, the health insurance issuer, not the employer sponsoring the plan, would have been required to obtain the HPID.

The final rule provided that the deadline for health plans (except small health plans) to obtain their HPIDs was Nov. 5, 2014. Small health plans (those with annual gross receipts of $5 million or less) had an additional year to comply, until Nov. 5, 2015. Also, the final rule provided that, by Nov. 7, 2016, all covered entities must use the HPID in standard transactions involving health plans that have an identifier.

Enforcement Delay

After issuing the final rule, HHS received feedback from the health care industry that the HPID’s implementation would be disruptive, costly and counterproductive to administrative simplification. According to industry experts, the confusion that the HPID was intended to address has already been resolved by the industry’s voluntary adoption of a standardized payer identifier, or payer ID.

Based on this feedback, Oct. 31, 2014, HHS delayed the enforcement of the HPID requirement until further notice. This enforcement delay meant that health plans were not required to obtain an HPID and covered entities were not required to use the HPID in standard transactions.

Proposed Rule

HHS’ proposed rule would officially rescind the final rule’s HPID requirements. According to HHS, its decision to withdraw the final rule stems from a careful assessment of industry input. This input demonstrates that:

  • The health care industry has developed best practices for using payer IDs to conduct HIPAA transactions. The HPID does not have a place in these transactions, and from the industry’s perspective, does not facilitate administrative simplification.
  • It would be a costly, complicated and burdensome disruption for the industry to have to implement the HPID.

HHS may explore options for a more effective standard unique HPID in the future.

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