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Notice of Proposed Rulemaking

On December 19, 2018, the Department of Health and Human Services (HHS) published a notice of proposed rulemaking (NPRM) - CMS-0054-P - to modify 45 CFR 162.103 and repeal 45 CFR 162.502-514 to rescind the adoption of the Health Plan Identifier (HPID) and Other Entity Identifier (OEID).  Following publication of the final rule in September 2012, HHS received feedback from stakeholders and the National Committee on Vital and Health Statistics (NCVHS) regarding provider burden, implementation costs, and inefficiencies.  On October 31, 2014, HHS announced an enforcement discretion, meaning covered entities would not be penalized for non-compliance with the HPID final rule.  During the comment period, and until a final rule is published, the enforcement discretion remains in effect for all covered entities. 

The proposed rule would eliminate the regulatory requirement for health plans to obtain and use an HPID as well as eliminate the voluntary acquisition and use of the OEID.  The proposed rule would also simplify the process for terminating the existing identifiers to minimize operational costs for covered entities. 

The proposed rule can be found here.  There is a 60-day public comment period for the rule, which closes on February 19, 2019.  We encourage industry stakeholders to read the proposed rule, share it with appropriate business associates, and submit comments.  These will assist us in preparing the final rule.  Instructions for submitting comments are provided on

If you have questions about other topics related to the adopted standards or operating rules, please send them to


The Health Plan Identifier (HPID) is designed to furnish a standard way to identify health plans in electronic transactions.

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 adopted 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 sub-health 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). 

As of October 1, 2014, CMS announced a delay, until further notice, in enforcement of rules for obtaining and using HPIDs.

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) 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 health care providers, health plans, and health care 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, health care providers and clearinghouses, and their business associates) not use the HPID in the HIPAA transactions. This enforcement discretion will allow HHS to review the NCVHS’s recommendation and consider any appropriate next steps.

HPID Request for Information (RFI)

HHS released an RFI on May 29, 2015, to solicit feedback from the health care community about the HPID. HHS is reviewing all comments received from the RFI.

Findings and Recommendations from the May 3, 2017 NCVHS Standards Subcommittee Hearing on the Health Plan Identifier.