Applicable Group Health Plans to obtain HPIDs


As part of the Affordable Care Act, group health plans that are “controlling health plans” must obtain a 10-digit health plan identifier (HPID) by November 5, 2014.  The HPID creates a standard data element for health plans and simplifies the routing, review and payment of electronic transactions and reduces errors and manual intervention. A self-funded plan would have to obtain an HPID whereas a fully insured plan does not.  Small health plans, those with annual receipts of $5 million or less, have an additional year to apply for a HPID.  Health reimbursement accounts (HRA) with 50 or more participants are considered self-funded plans under HIPAA and will need to obtain an HPID if they have a fully insured group health plan.


  • November 5, 2014: Large health plans must obtain HPID number
  • November 5, 2015: Small health plans must obtain HPID number
  • November 7, 2016: Health plans must use HPID in standard transactions

For more information on HPIDs and the application process, visit the CMS website at

As the deadline to apply for an HPID nears, William Gallagher Associates will provide our clients with further information.

If you have any questions, please contact your WGA’s Compliance Team