Benefit News

HPID Requirement Delayed Indefinitely

October 1, 2014

On October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) announced that enforcement of the Health Plan Identifier (HPID) requirement is delayed until further notice.

The HPID is a standard, unique health plan identifier required by the Health Insurance Portability & Accountability Act of 1996 (HIPAA). The initial deadline for large group health plans to obtain an HPID was November 5, 2014. Small group health plans (those with annual gross receipts of $5 million or less) were given until November 5, 2015 to comply.

This delay applies to both the requirement that health plans obtain an HPID and the use of the HPID in HIPAA standard transactions, and 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.

Indefinite Delay of the HPID Rules

The CMS Office of e-Health Standards and Services (OESS) is responsible for enforcement of compliance with the HIPAA standard transactions, code sets, unique identifiers and operating rules, including the HPID requirement. The OESS issued a Statement of Enforcement Discretion, which provides that, effective as of October 31, 2014, there is a delay, until further notice, in enforcement of the regulations pertaining to the process of obtaining an HPID and use of the HPID in HIPAA transactions.

This enforcement delay applies to all HIPAA covered entities, including healthcare providers, health plans and healthcare clearinghouses.The OESS statement explained that the delay was prompted by a recommendation of the National Committee on Vital and Health Statistics (NCVHS), an advisory body to HHS. On September 23, 2014, the NCVHS had recommended that HHS provide in rulemaking that all HIPAA covered entities and their business associates not use the HPID in HIPAA transactions. The NCVHS instead recommends that the standardized national payer identifier based on the National Association of Insurance Commissioners (NAIC) identifier continue to be used. The enforcement discretion announced by OESS will allow HHS to review the NCVHS's recommendation and consider any appropriate next steps.

For additional information, please contact your Burnham Benefits Consultant, Burnham Benefits at 949-833-2983, or

Back to Updates