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Client Alert: HIPAA HPID Deadline Delayed until Further Notice

On the eve of the HPID November 5, 2014 deadline, CMS announced that enforcement of the HPID requirements is delayed, until further notice. “Effective October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) Office of e-Health Standards and […]


Fraser Trebilcock Employee Benefits Attorney Health Care Law HIPAAOn the eve of the HPID November 5, 2014 deadline, CMS announced that enforcement of the HPID requirements is delayed, until further notice.

“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 LINK for more). This enforcement discretion will allow HHS to review the NCVHS’s recommendation and consider any appropriate next steps.”

For more information, click this LINK.

You can access the government’s FAQs about HPIDs by clicking HERE.

This alert serves solely as a general summary of the newly released guidance. 


Elizabeth H. Latchana, Attorney Fraser TrebilcockElizabeth H. Latchana specializes in employee health and welfare benefits. Recognized for her outstanding legal work, in both 2018 and 2015, Beth was selected as “Lawyer of the Year” in Lansing for Employee Benefits (ERISA) Law by Best Lawyers, and in 2017 as one of the Top 30 “Women in the Law” by Michigan Lawyers Weekly. Contact her for more information on this reminder or other matters at 517.377.0826 or elatchana@fraserlawfirm.com.