Health Plan Identifiers (HPID) FAQs

HIPAA and Health Care Reform require that health plans obtain a federally assigned identification number. Similar to the identification numbers, already required of providers, these uniformly formatted numbers will be used to assist in HIPAA transactions. In essence, they are to assist in standardizing transactions amongst different types of entities.

The HPID is a 10-digit, all numeric code similar to a credit card number. In addition to the use for standardized transactions, information about health plans and their HPIDs will be available in a public database to facilitate routing of transactions.

When and who must a health plan obtain a Health Plan Identifier (HPID)?

All health plans will have to obtain an HPID. Large Health Plans, which are defined as those health plans having receipts of at least $5 million will have to obtain their HPIDs by November 5, 2014.  Small health plans, those with receipts of less than $5 million, will have to obtain their HPIDs by November 5, 2015. Insurance issuers will obtain HPIDs on behalf of fully insured plans, while plan sponsors will be responsible for obtaining HPIDs on behalf of self-funded plans.

Type of Plan Compliance Date for Obtaining HPID Implementation Date for Use of HPID in Standard Transactions
Large Health Plans November 5, 2014 November 7, 2016
Small Health Plans* November 5, 2015 November 7, 2016

*A small health plan is a plan that pays less than $5 million in benefits per year.

How to determine if receipts are less than $5 million?

Health plans that file certain federal tax returns and report receipts on those returns should use the guidance provided by the Small Business Administration at 13 Code of Federal Regulations (CFR) 121.104 to calculate annual receipts.   Health plans that do not report receipts to the Internal  Revenue Service (IRS), for example, group health plans regulated by the Employee Retirement Income Security Act 1974 (ERISA) that are exempt from filing income tax returns, should use proxy measures to determine their annual receipts.

Fully insured health plans should use the amount of total premiums that they paid for health insurance benefits during the plan’s last full fiscal year.   Self-insured plans, both funded and unfunded, should use the total amount paid for health care claims by the employer, plan sponsor or benefit fund, as applicable to their circumstances, on behalf of the plan during the plan’s last full fiscal year.  Those plans that provide health benefits through a mix of purchased insurance and self-insurance should combine proxy measures to determine their total annual receipts.

How do I obtain a Health Plan Identifier (HPID)?

In order to enumerate (obtain an HPID), a health plan should:
1. Create an account in the CMS Enterprise Portal to obtain a user ID and password.
2. Select the link to register in the Health Insurance Oversight System (HIOS).
3. After registering in HIOS, select the link for the Health Plan and Other Entity Enumeration System (HPOES), and follow the prompts.

We have posted a User Manual and a Systems Quick Guide to help you navigate to HPOES.

Who is the controlling health plan (CHP) for Fully-Insured Plans?

The Health Insurance Issuer (Carrier) is the entity that controls the fully-insured controlling health plan (CHP).  Since all CHPs are required to obtain HPIDs, the carrier must obtain the HPID for the fully-insured plan.  The individual employer plans are sub health plans (SHPs) to the fully-insured CHPs.  Per regulation, SHPs may obtain HPIDs, but are not required to.

A controlling health plan (CHP) must obtain an HPID by November 5, 2014, unless it is a small health plan (annual receipts of $5 million or less).  Small health must obtain an HPID by November 5, 2015.




The information provided herein is intended solely for the use of our clients. You may not display, reproduce, copy, modify, license, sell or disseminate in any manner any information included herein, without the express permission of the Publisher or Publishers of articles within.

The information provided is for informational purposes only and does not constitute legal advice. The information above contains only a summary of the applicable legal provisions and does not purport to cover every aspect of any particular law, regulation or requirement. Depending on the specific facts of any situation, there may be additional or different requirements. This is to be used only as a guide and not as a definitive description of your compliance obligations.