HPID Requirement Delayed Until Further Notice

The Health Plan Identifier (HPID) is a standard, unique health plan identifier required by the Health Insurance Portability & Accountability Act of 1996 (HIPAA). The initial deadline for health plans to obtain an HPID was Nov. 5, 2014.

On Oct. 31, 2014, the Centers for Medicare & Medicaid Services (CMS) announced that enforcement of the HPID requirement is delayed until further notice. This delay applies to:

  • The requirement that health plans obtain an HPID; and
  • The use of the HPID in HIPAA standard transactions.

This enforcement delay means that health plan sponsors who are subject to the HPID requirement and have not yet received their HPIDs can hold off for now.

CMS has not indicated if there will be a new deadline for obtaining the HPID, or when the new deadline will be. Health plan sponsors who have already obtained HPIDs should maintain a record of their identifier.

Initial HPID Deadlines

The initial 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) were given an additional year to comply, until Nov. 5, 2015.

By Nov. 7, 2016, all covered entities were to use the HPID in standard transactions involving health plans that have an identifier.

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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.