13 November 2019

Do You Remember The HPID Requirement? Good, Now You Can Forget It.

The Department of Health and Human Services (HHS) recently issued regulations repealing the Health Plan Identifier (HPID) requirement for group health plans.  Since we anticipate that many plan sponsors forgot about the HPID requirement because it was delayed on October 31, 2014, we suspect that the repeal will come as a welcome surprise to most plan sponsors.


Under the Affordable Care Act, large group health plans were required to obtain an HPID by November 5, 2014.  Small group health plans—which are group health plans with “annual receipts of $5 million or less”—had an additional year, until November 5, 2015, to obtain an HPID.  Other entities, such as third-party administrators of group health plans, were not required to obtain an identifier, but could voluntarily apply for an Other Entity Identifier (OEID).  The purpose of an HPID and OEID was to identify the various parties in a HIPAA standard transaction.

Insurance carriers of fully insured group health plans were required to obtain the HPID on behalf of fully insured group health plans.  But, plan sponsors of self-funded group health plans—including health reimbursements arrangements and medical flexible spending accounts—were required to obtain the HPID on behalf of self-funded group health plans.


For those plan sponsors who attempted (and the few that were successful in) obtaining an HPID, you likely remember the hair-pulling experience required to do so.  In fact, the process was so difficult that on October 31, 2014—just six days before large group health plans were required to obtain an HPID—HHS indefinitely delayed the HPID requirement for all group health plans.


On October 28, 2019, HHS issued final regulations, effective December 27, 2019, repealing the HPID requirement and the ability for other entities to obtain an OEID.  HHS is repealing the HPID and OEID because it found that—due in large part to “Payer IDs”—the HPID and OEID are unnecessary to identify the parties to HIPAA standard transactions.  For instance, despite the delay of the HPID requirement in October of 2014, group health plans have been consistently engaging in HIPAA standard transactions without identification issues using only a Payer ID.

Next Steps

Fortunately, plan sponsors of group health plans do not have to take any action in response to the final HPID regulations.  According to the preamble to the final regulations, HHS will automatically deactivate all HPIDs and OEIDs on December 27, 2019 and notify the designated contacts in the Health Plan and Other Entity Enumeration System (HPOES), which was the system used to obtain HPIDs and OEIDs.  HPOES will remain open until February 25, 2020 for plan sponsors and other entities to view and record information about their HPID and OEID.  HHS also stated that they will continue to review the necessity of a unique identifier for group health plans in the future but will engage the industry in that review.

If you have any questions regarding HPIDs or OEIDs, please contact the author or any member of the Employee Benefits Practice Group.