Healthcare Payments Data Program: Voluntary Submitters

Healthcare Payments Data Program (HPD) Overview

The HPD is California’s all payer claims database (APCD), a resource that compiles data on health care services in California to increase transparency and inform policy. An overview of the HPD and a broad set of FAQs are available on HCAI’s website addressing topics including timeline, types of data and format, stakeholder engagement, privacy and security, and access to HPD data. Resources for data submitters are also available.

HPD Program Goals

The HPD Program has developed the following goals, based on the legislative intent outlined in the authorizing statute.

  • Provide public benefit for Californians and the state while protecting individual privacy.
  • Increase transparency about health care costs, utilization, quality, and equity.
  • Inform policy decisions on topics including the provision of quality health care, improving public health, reducing disparities, advancing health coverage, reducing health care costs, and oversight of the health care system and health care companies.
  • Support the development of approaches, services and programs that deliver health care that is cost effective, responsive to the needs of Californians, and recognizes the diversity of California and impacts of social determinants of health.
  • Support a sustainable health care system and more equitable access to affordable and quality health care for all.

Voluntary Submission to the HPD

Many health benefit programs are increasingly concerned about the continued escalation of health care costs and are interested in more effective use of data and transparency to drive the development of solutions. An estimated 4-5 million Californians are covered by ERISA self-funded employers and other purchasers, which are not mandatory submitters under the HPD Program (see FAQ for details). These purchasers may choose to contribute their data to the HPD. The more comprehensive the HPD is in reflecting the entire population of California, the more accurate the analytic findings will be and the greater the likelihood of achieving both purchaser goals and HPD program goals – including transparency, informed policy decisions, improved health care, and equitable access to affordable and high-quality care.

Purchasers can request their ASO plan(s) that their data be submitted to HPD. Click below to request assistance connecting with your ASO.

What Can Employers Learn from HPD Data?

While the HPD ramps up and begins being populated with data and establishing its public reporting program, visualizations and reports from other state APCDs provide examples of the types of data products that could be developed by HPD to help employers and other purchasers identify cost-saving and health improvement opportunities.

  • Medicare Reference Pricing: Oregon’s interactive visual displays hospital prices in the commercial market relative to Medicare for common procedures. In 2019, commercial plans paid, on average, 178% of Medicare fee-for-service rates for inpatient services and 247% for outpatient hospital services. 
  • Price Variation: At the request of the Colorado Purchasing Alliance, Colorado’s Center for Improving Value in Health Care (CIVHC) conducted a site-of-care analysis comparing the cost of 10 outpatient surgical procedures provided in a hospital-based setting vs. a free-standing facility. The analysis found average savings of 44% in moving site of care from the hospital to a free-standing facility.
  • Low Value Care: CIVHC produces a series of employer-specific reports for employers submitting data to the APCD, one of which focuses on low-value care. Statewide, $140 million is spent on low-value care, of which patients were responsible for over $17M (12%); three services accounted for 44% of total low-value care spending.
  • Prescription Drug Pricing: Massachusetts’ Center for Health Information and Analysis (CHIA) created an interactive dashboard on commercial market prescription drug use and spending that allows drill-down on top therapeutic classes. The 10 largest therapeutic classes accounted for over 70% of prescription drug spending. 
  • APCD Council Showcase – Employers: The All-Payer Claims Database Council, a learning collaborative of government, private, non-profit, and academic organizations involved with all payer claims databases (APCDs), has compiled use cases by audience, including a category specific to employers.

Voluntary Submission Frequently Asked Questions

1. Are ERISA self-funded employers and other purchasers required to submit data to the HPD?

No. As currently written the Health and Safety Code authorizing the implementation of the HPD Program does not include entities subject to ERISA as mandatory submitters to the HPD Program.  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 and other purchasers, such as Taft-Hartley trusts (collectively bargained labor-management agreements).

2. Aren’t CalPERS and other public purchasers also self-funded? Are they required to submit data?

The Gobille v. Liberty Mutual decision does not apply to governmental plans that cover public employees because such plans are exempt from ERISA. Accordingly, the California Health and Safety Code authorizing the implementation of the HPD Program, identifies 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) as mandatory submitters to the HPD System if they meet the threshold for size. HCAI has set a threshold of 40,000 covered lives to define mandatory submitters, so public purchasers with fewer than 40,000 self-funded members and dependents fall below that threshold and are not required to submit their data.

3. Are ERISA self-funded employers and other purchasers allowed to submit data to the HPD system?

Yes. California law gives HCAI the authority, at its discretion, to accept data voluntarily submitted to the HPD System, including data from ERISA self-insured plans. Also, HCAI believes HIPAA covered entities can disclose protected health information (PHI) to HCAI without patient authorization based on exceptions in HIPAA enabling covered entities to disclose PHI for public health activities as described in 45 C.F.R. 164.512(b), or for health oversight activities authorized by law under 45 C.F.R. §164.512(d).

California law states that the HPD program “performs public health activities” and that the information collected for HPD is “necessary to carry out projects with public health purposes.”  Specifically, the HPD’s purpose is to collect PHI “to inform state policy decisions regarding the provision of quality health care, improving public health, reducing disparities, advancing health coverage, reducing health care costs, [and] oversight of the health care system and health care companies.”    

Please be aware that the above information is not intended to convey or constitute legal advice.  Please consult your legal counsel about your specific circumstances.

4. How can an ERISA self-funded employer or other purchaser submit data to the HPD system?

The purchaser’s TPA/ASO (third party administrator/administrative services only) partner(s) can submit the data on your behalf, with your authorization. The TPA/ASO may be contacted directly to make this request, or purchasers may complete the HPD Request Assistance Form for more information on how to facilitate data submission through the TPA/ASO. The HPD Regulations also outline the process to become a voluntary submitter, and can be accessed here.

Click here to request assistance connecting with your ASO.

5. How do ASO plans generally obtain authorization from clients to submit data to HPD?

Some plans engage their clients proactively on about contributing data to HPD (and other state APCDs) by explaining the opportunity and providing an opt-in authorization as part of new client onboarding and/or annual renewal processes. Other plans rely on requests from their clients to trigger the authorization and opt-in process and respond to those requests individually as they arise.

Purchasers can request their ASO plan(s) that their data be submitted to HPD. Click here to request assistance connecting with your ASO.

6. 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.

To read more about how the HPD program will ensure data privacy, confidentiality, and security, please see FAQ #12 on the HPD webpage.

7. Who will have access to HPD data?

HCAI will establish a process to prevent any unauthorized use of the data. Data requestors can apply for access to more detailed data that is not publicly accessible. These requests will be reviewed by  the  data release committee, to be convened in 2023, that will make recommendations to HCAI regarding the release of any requested data that is not publicly available and includes direct identifiers or involves the transmission of data outside the enclave. The HPD data access framework, data access objectives, and data release committee were discussed at the January and April 2022.



Contact HPD at  for additional HPD questions or inquiries.   

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