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Health Plan Identifier

Health Plans 

The Health Plan Identifier (HPID) is a standard, unique health plan identifier required by the Health Insurance Portability & Accountability Act of 1996 (HIPAA).  On September 5, 2012 the Department of Health and Human Services (HHS) published the final rule (CMS-0040F) which adopts a unique identifier (HPID) for Health Plans.  The Final Rule for Transactions and Codes Sets provides a definition for health plan at 45 CFR 160.103, which references  42 U.S. Code § 300gg–91 - Definitions.  For the purposes of HPID enumeration, health plans are divided into controlling health plans and subhealth plans, two of several new terms introduced in the final rule.  Other new terms include Other Entity Identifier (OEID); Health Plan and Other Entity Enumeration System (HPOES) and Health Insurance Oversight System (HIOS).

Compliance Deadlines

  • Controlling Health plans (except small health plans) are required to obtain HPIDs by November 5, 2014.
  • Small controlling health plans, not to be confused with sub-health plans (SHPs) are required to obtain HPIDs by November 5, 2015.  
    • A small health plan is one with $5 million or less in annual receipts. Plans that do not report annual receipts to the IRS should use one of the following proxy measures to determine annual receipts:
      • The amount of total premiums that they paid for health insurance benefits during the plan’s last full fiscal year.
      • 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.
      • For plans that provide health benefits through a mix of purchased insurance and self-insurance, combine proxy measures to determine total annual receipts.

Statement of Enforcement Discretion regarding 45 CFR 162 Subpart E - Standard Unique Health Identifier for Health Plans

Effective October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) Office of e-Health Standards and Services (OESS), the division of the Department of Health & Human Services (HHS) that is responsible for enforcement of compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) standard transactions, code sets, unique identifiers and operating rules, announces a delay, until further notice, in enforcement of 45 CFR 162, Subpart E, the regulations pertaining to health plan enumeration and use of the Health Plan Identifier (HPID) in HIPAA transactions adopted in the HPID final rule (CMS-0040-F). 

This enforcement delay applies to all HIPAA covered entities, including healthcare providers, health plans, and healthcare clearinghouses.

On September 23, 2014, the National Committee on Vital and Health Statistics (NCVHS), an advisory body to HHS, recommended that HHS rectify in rulemaking that all covered entities (health plans, healthcare providers and clearinghouses, and their business associates) not use the HPID in the HIPAA transactions (see This enforcement discretion will allow HHS to review the NCVHS’s recommendation and consider any appropriate next steps.

HPID Enumeration 

Enumeration is the process of getting an HPID.  All Controlling Health Plans (CHPs) must enumerate.   Third-party administrators are not eligible to obtain HPIDs for themselves, but may submit HPID requests in the Health Plan and Other Entity Enumeration System (HPOES) on behalf of their health plan customers. View the data elements that will be collected for HPID (CHP and SHP) and OEID applications and the subhealth plan category definitions.

How to apply for a Health Plan (HPID) and Other Entity Identifier (OEID)?

HPIDs and OEIDs can be obtained through the Health Plan and Other Entity Enumeration System (HPOES). HPOES is housed within the CMS Health Insurance Oversight System (HIOS).

To apply for an HPID or OEID, follow these steps:

  • First, you must create an account in the CMS Enterprise Portal to obtain a user ID and password.  This is a separate process and system which will verify the user’s identity and ensure that only authorized/registered users will access protected information and systems.
  • Second, select the link to register in the HIOS.  Registering in HIOS may take up to 48 hours to complete as it involves a manual review of submitted information.
  • After registering in HIOS, select the HPOES, and follow the prompts.  If you have any system related questions, please contact the Exchange Operations Center at phone: 1-855-267-1515 or Email:

If you need help getting an HPID

There is an HPID User Manual (10, 092 KB) and a Quick Guide available.  The user manual explains the user functionality of the HPOES module within the Health Insurance Oversight System (HIOS).  This manual provides step-by-step instructions for the features and functionalities available in HPOES.  

The Quick Guide provides an easy step-by-step reference for registering in the CMS IT system and accessing HPOES.  You can view the Quick Guide in graphic or text form. 

Questions about the HPID

HPID Frequently Asked Questions (FAQs)-HPID FAQs are posted on the CMS website and continue to be updated as new information is available.  

HPID Mailbox -If you have policy questions about HPIDs and OEIDs, you can contact CMS through the HPID Mailbox at