Health Plan Identifier (HPID)

The U.S. Department of Health and Human Services (HHS) has published the final rule addressing the adoption of a unique standard Health Plan Identifier (HPID) for use in HIPAA standard transactions, effective Nov. 7, 2016. To comply, self-funded health plans, excluding small health plans, must obtain an HPID by Nov. 5, 2014. Self-funded small health plans must obtain an HPID by Nov. 5, 2015. (HIPAA defines a small health plan as one with annual receipts of $5 million or less.)

What is a HPID?
Beginning Nov. 7, 2016, health plan’s HPID must be used when the health plan is identified in a HIPAA standard transaction. It is intended to provide consistency and a standard format for health plans to identify themselves.

Two new categories of plans
Two new categories of health plans, as defined in the HIPAA regulations, are:

Controlling Health Plan (CHP)
A CHP is a health plan that:

  • controls its own business activities, actions or policies; or
  • is controlled by an entity that is not a health plan;
  • if it has a subhealth plan(s), exercises sufficient control over the subhealth plan(s) to direct its business activities, actions, or policies.

Subhealth Plan (SHP)
A SHP is a health plan that has business activities, actions or policies directed by a controlling health plan.

What types of plans must obtain a HPID?
All controlling health plans are required to obtain a HPID.

The following chart outlines the required time frames for compliance with HPID requirements.

Entity Type

Compliance Date

for Obtaining HPID

Full Implementation Date
for Using HPID in
Standard Transactions

Health plans, excluding small health plans

Nov. 5, 2014

Nov. 7, 2016

Small health plans

Nov. 5, 2015

Nov. 7, 2016

Covered healthcare providers

Not applicable

Nov. 7, 2016

Healthcare clearinghouses

Not applicable

Nov. 7, 2016

Note: When the HPID application asks for a Payer ID, CoreSource clients should type, “Not applicable.”

Health Plan Identifier (HPID) Requirements