Health Care Payments Data (HPD)

FAQ#

1. How will the HPD Program contribute to improving California’s healthcare system?

In gathering, integrating, and organizing information about how health plans and insurers pay for care, the HPD Program offers an unprecedented opportunity to address health care costs and drive improvement in California’s healthcare system. The HPD System can provide visibility into how California spends $400 billion on health care annually; streamline and improve California’s ability to monitor health system performance through more complete and standardized data; and enable a better, lower-cost approach to planning and evaluating programs and improvement initiatives. The variety and volume of data the HPD System will collect and link to will increase over time, as will the complexity of supported analyses.

2. What data does the HPD System collect?

The HPD System currently collects administrative data, including claims and encounters generated by transactions among payers and providers on behalf of insured individuals. This includes the following data files: Member Eligibility, Medical Claims, Pharmacy Claims, Dental Claims, and Provider Data.

Beginning on March 25, 2025, The HPD System will collect Non-Claims Payment (NCP) data, including Capitation Files, Annual Payment Files, and Pharmacy Rebate Files. Please see the Non-Claims Payment Fact Sheet for additional information and expected rulemaking timeline.

3. What format is used to collect the data?

The HPD Program adopted a national standard created by the APCD Council, the APCD Common Data Layout ^TM (APCD-CDL^TM), for commercial submitters and for Medi-Cal claim and encounter data. A standardized format reduces burden for data submitters, particularly payers that submit data to multiple state APCDs.

As of March 25, 2025, the HPD Program will collect Non-Claims Payment data using the NCP Data Layout^TM version 1.0, created by the APCD Council, NAHDO, and University of New Hampshire. This layout aims to harmonize NCP data collection efforts across states and reduce the burden of data submission.

4. Who submits data to the HPD System? 

The HPD collects claim and encounter data from healthcare payers such as health plans, insurers, and dental plans. The HPD Program collects healthcare data for over 30 million Californians each year sourced from: the Department of Health Care Services (DHCS) for Medi-Cal members; the Centers for Medicare & Medicaid Services (CMS) for Medicare fee-for-service members; and health plans and insurers for those with employer-based, individual, or Medicare Advantage coverage. Private, self-insured companies interested in reducing costs and improving system performance will be encouraged to participate in the HPD Program on a voluntary basis.

5. What about private self-insured companies and Taft-Hartley trusts?

In March 2016, the U.S. Supreme Court ruled that states cannot require self-insured employer plans regulated under the federal Employment Retirement Income Security Act of 1974 (ERISA) to submit data to a state APCD. The decision, Gobeille v. Liberty Mutual, resulted from a lawsuit by a self-insured employer that challenged Vermont’s right to require the employer’s third-party administrator to submit claim data to the state APCD. The Supreme Court found that ERISA preempted Vermont’s ability to compel the submission of claim data for self-insured employers. The decision does not apply to governmental plans that cover public employees because such plans are exempt from ERISA. Accordingly, self-insured health benefit programs for state employees and other public workers (including state, county, and municipal employees and retirees; and public-school teachers and retirees) can be included as mandatory submitters to the HPD System. 

While private self-insured employers and Taft-Hartley trusts (collectively bargained labor-management agreements) cannot be compelled to contribute data to the HPD System, many health benefit programs are increasingly concerned about the continued escalation of health care costs and are interested in using analytics based on APCDs to contribute to the development of solutions.

HCAI has the authority, at its discretion, to accept data voluntarily submitted to the HPD System, including data from hospitals, clinics, and clinicians with an independent scope of practice who submit claims electronically, and ERISA self-insured plans. 

6. Will the HPD System include data from other sources?

Other data sources can enhance the ability of the HPD System to answer important questions that cannot be addressed with claim and encounter data alone. HCAI will ensure that the HPD System can map to other datasets, including public health datasets on morbidity and mortality and data regarding the social determinants of health. On July 1, 2024, the HPD Advisory Committee made public health data recommendations regarding integrating state public health data with the HPD System.

7. Who can access HPD data?

The public can access HPD data through publicly available information, including data products and analytic that HCAI produces from the database. In addition, applications are now open for access to non-public HPD data. To apply for HPD datasets, please begin by registering an account on the HCAI Data Request Portal. Visit the HPD Data Access and Release for complete application instructions and more information.

8. How will access to non-public data be handled?

Please visit the HPD Data Access and Release to learn more about how to access non-public data. Individual patient-level data is exempt from the disclosure requirements of the California Public Records Act.  

9. What is HCAI’s Secure Data Enclave?

The HCAI Secure Data Enclave is a centralized service to remotely access sensitive data. It houses data in a secure environment and protects that data in accordance with state and federal security and privacy rules. The enclave provides a scalable environment, so a user can analyze a large volume of data regardless of their personal computer and storage resources. Data in the enclave is accessed via a virtual machine operating on a remote server and launched from the user’s computer. The virtual machine is controlled by HCAI so that data products created on it can only be downloaded to the user’s computer with HCAI’s permission. Users cannot copy/paste, email out, or otherwise remove data from the Enclave. Only after HCAI verifies that the data products align with the user’s approved request and with CalHHS Data De-Identification Guidelines can they be downloaded to the user’s computer.

A user’s experience in the enclave is tailored to their data request. HCAI’s enclave makes the approved data available to approved users for approved projects. The data for each project in the enclave is segregated from other projects’ data. Authorized users can upload and link their own datasets into the enclave and link their data to the HPD dataset. Enclave users will have access to interactive, query-based tools, and statistical tools (e.g., SQL, SAS, Stata, R, Python).

The HCAI Secure Data Enclave is under development. Contact hpd@hcai.ca.gov with questions.

10. How will the HPD program ensure data privacy, confidentiality, and security?

With the establishment of the HPD program, HCAI is implementing further specific privacy and security protocols to safeguard the health care data of Californians. Chapter 8.5 (commencing with Section 127671) of Part 2 of Division 107 of the Health and Safety Code establishes strong privacy and security standards for the HPD System.

Access to personally identified data collected by the HPD is only authorized for eligible uses and after appropriate approvals have been granted. Only eligible and authorized entities, such as university researchers, may obtain appropriate access to individual-level data for the purposes of data linkage and longitudinal research study. The HPD data may not be used for determinations regarding individual patient care or treatment nor for any individual eligibility or coverage decisions. The HPD data are exempt from the California Public Records Act.

HCAI is required to convene a Data Release Committee made up of representatives of health care payers, providers, suppliers, purchasers, researchers, consumers, and labor. The Data Release Committee makes recommendations to HCAI on release of HPD data to authorized entities. Members of the Data Release Committee are required to have experience with health care data, privacy, and security and will provide input on policies and procedures related to controlling access to non-public data. The use of a secure data enclave will further ensure the security and confidentiality of the data. The Data Release Committee must review all requests for access outside the secure data enclave. For considering use outside the enclave, enhanced security and privacy controls will need to be met. Before accessing the data, requestors will be required to sign the HPD Data Use Agreement that requires recipients of HPD data to maintain its security and protect consumer privacy. To learn more about how HCAI protects the data we receive and manage, please visit the HCAI Data Resources Webpage.

11. What is the budget and funding source for the HPD Program?

The HPD System will be a statewide resource and will require investment to build and operate. HCAI was appropriated $60 million in General Fund monies from the 2018-2019 Budget Act (Chapter 23, Statutes of 2019) to fund the implementation and operation of the HPD program.

Upon exhaustion of the $60 million allocation, HCAI will utilize a multi-faceted approach to fund the program including partnering with DHCS to maximize federal financial participation from the Medicaid program and charging data user fees. The Department may also accept funding from foundations not affiliated with or controlled by a healthcare entity. HCAI will need to develop a long-term funding mechanism to sustain the program. In March 2023, HCAI submitted a report to the Legislature on recommendations for funding options for the program. Read the funding options report.

12. How is the Office of Health Care Affordability different from the Health Care Payments Data Program?

The Office of Health Care Affordability (OHCA) will track aggregate cost growth and assess the performance of health care entities against the cost growth target. It is anticipated that data will be submitted annually. OHCA will collect total health care expenditure data broken down by service category (e.g., hospital, physician services, prescription drugs, etc.). As in all states that have both a cost growth target program and an APCD, OHCA will require supplemental data submission to capture information not available in the HPD.

OHCA and the HPD Program will collaborate on data collection and reporting to ensure efforts are complementary. For example, OHCA will rely on the HPD System for detailed analyses of cost drivers. To the extent feasible, standards and measures for topics such as alternative payment models and primary care spending will align across the two programs.

13. How is the HPD Program different from health information exchange?

Electronic health information exchange allows healthcare providers, including doctors, nurses, and pharmacists, to appropriately access and securely share a patient’s medical information to improve patient care. Some health information exchange organizations (HIOs) also provide enhanced services such as longitudinal patient records, event notifications, analytics, and public health and/or clinical quality measure reporting. Whereas HIOs enable the real-time, transactional exchange of patient clinical data for care coordination among providers, the HPD will collect administrative data (claims and encounters) from payers for retrospective analyses of California’s healthcare system. The health care payments data are intended to support cost transparency efforts as well as to inform policy decisions regarding the provision of health care and reduce healthcare costs and disparities. 

14. Is HCAI’s HPD Program required to sign a HIPAA attestation regarding reproductive health care as discussed in 45 CFR 164.509? 

No, based on federal regulation and California law, HCAI is not required to sign the HIPAA attestation form to obtain data from mandatory submitters for the HPD program.  The U.S. Health and Human Services’ Office of Civil Rights states, “the attestation condition does not apply to the mandatory disclosures made pursuant to 45 CFR 164.512(a)”.  HCAI obtains personal health information for the HPD program from HIPAA covered entities under 45 CFR 164.512(a)(1). The HPD program collects medical claims and encounters, pharmacy claims, dental claims , eligibility, and provider data from commercial health plans and insurers, the California Department of Health Care Services, and the Center for Medicare and Medicaid Services as required by California Health and Safety Code Section 127671-127674.1 and California Code of Regulations Title 22, Division 7, Chapter 11.  

The California Constitution (Article 1, Section 1.1) and the California Reproductive Privacy Act (Health and Safety Code sections 123460-123469) provide additional protection regarding reproductive health.  

If a mandatory submitter has any questions, please reach out to hpd@hcai.ca.gov for assistance.