The Health Care Payments Database (HPD) is California’s All Payer Claims Database or APCD. The HPD is a research database comprised of healthcare administrative data: claims and encounters generated by transactions among payers and providers on behalf of insured individuals. The HPD collects claim and encounter data as submitted from California payers.

The information from the HPD System is intended to support greater health care cost transparency and will be used to inform policy decisions regarding the provision of quality health care, and to reduce health care costs and disparities. It is also intended for the information to be used to develop innovative approaches, services, and programs that may have the potential to deliver health care that is both cost effective and responsive to the needs of all Californians.

To maximize its utility and value for California policymakers, researchers, and others interested in improving California’s healthcare system, HCAI intends for the HPD to be as comprehensive and complete as possible by increasing the quality, volume, and variety of data collected over time.

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 consumer 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 enrollees, and recognizes the diversity of California and impacts of social determinants of health.
  • Improve data transparency to achieve a sustainable health care system and more equitable access to affordable and quality health care for all.
  • Learn about and seek to improve public health, population health, social determinants of health, and the health care system, not about individual patients.

Laws and Regulations

AB 80 (Chapter 12, Statutes of 2020) provides HCAI the authority to establish the Health Care Payments Data (HPD) Program. This enabling legislation expands the mandate provided by AB 1810 (Chapter 34, Statutes of 2018), which included a one-time appropriation for HCAI to develop and administer the program and required HCAI to convene a Review Committee of stakeholders and experts to advise the department on the establishment, implementation, sustainability, and ongoing administration of the HPD Program. The Review Committee’s recommendations were included in a report submitted to the California Legislature on March 9, 2020.

Health and Safety Code, Division 107, Part 2, Section 8.5 provides HCAI the authority to implement the HPD Program to collect health care data from health care plans, health insurers, government agencies and others (Health and Safety Code Section 127671.1). 

The Certificate of Compliance of the HPD Program Data Collection Regulations has been approved by the Office of Administrative Law, and the regulations are in effect as of November 17, 2023. The Certificate of Compliance makes permanent the December 2021 HPD Program emergency regulations that established procedures for health care data collection and submission. The permanent regulations are posted on the California Code of Regulations Westlaw website. The Notice of Approval of Certificate of Compliance and other associated documents are linked below.


The following are resources for the Health Care Payments Data Program:


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. To be as comprehensive as possible and to maximize its utility and value for California policymakers and others interested in improving California’s healthcare system, the HPD Program will expand its data collection efforts to include Non-Claims Payment data. 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-CDLTM), 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.

4. Who submits data to the HPD System? 

The HPD collects claim and encounter data from healthcare payers such as health plans and insurers. 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. The HPD statute requires that the advisory committee make recommendations to HCAI by July 2024 regarding how state public health data functions may be integrated into 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, HCAI will establish a process through which data requestors can apply for access to more detailed, non-public data.

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

HCAI, with the advice of the Advisory Committee and the Data Release Committee, will develop criteria, policies, and procedures for access and release to non-public data, including data aggregation and the protection of individual confidentiality, privacy, and security. 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.

As data are collected and managed, HCAI will convene a Data Release Committee made up of representatives of health care payers, providers, suppliers, purchasers, researchers, consumers, and labor. The Data Release Committee will make 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. 

HPD Public Reporting

HCAI is required to produce publicly available information from the database, including data products and analytic reports, to support the goals of the program. The HPD Advisory Committee is responsible for advising HCAI on principles and priorities for public reporting.

HCAI anticipates continuing to advance the accessibility and usefulness of HPD public reports as the database becomes more comprehensive and complete and HCAI builds its capacity over time.

HPD Stakeholder Engagement

HPD Program Advisory Committee

HCAI is required to convene an HPD Program Advisory Committee comprised of health care stakeholders and experts to assist and advise the HCAI Director in formulating program policies regarding data collection, management, use, access, and development of public information to meet the goals of the HPD Program. The committee does not have decision-making authority related to the administration of the database but will serve as a forum for stakeholder and public engagement on policy decisions, while fostering accountability and transparency.

HPD Data Release Committee

HCAI is required to convene a Data Release Committee (DRC) to advise on requests for access to non-public data.

The DRC is an integral part of the HPD Program and will be supporting HCAI to:

  • Lay the foundation for HPD data access and release and contribute to the launch of an effective and credible Data Release Program
  • Advise HCAI on relevant policies and processes
  • Participate in thoughtful deliberation to weigh broad use of HPD data and public benefit to Californians with protection of patient privacy  
  • Review and make recommendations to HCAI on access to and release of non-public HPD data

The DRC is made up of subject matter experts representing key stakeholder groups including: consumers, labor, providers (both at clinician and hospital levels), payers, purchasers, suppliers, and researchers.

HPD Program Data Submitters

The enabling legislation identifies the following entities as mandatory submitters to the HPD:  

  • Health care service plans, including a specialized health care service plan. 
  • Insurers licensed to provide health insurance, as defined in Section 106 of the Insurance Code. 
  • Self-insured plans subject to Section 1349.2, or a state entity, city, county, or other political subdivision of the state, or a public joint labor management trust that offers self-insured or multiemployer-insured plans that pay for or reimburse any part of the cost of health care services. 
  • The State Department of Health Care Services, for those enrolled in Medi-Cal and other insurance affordability programs, whether enrolled in Medi-Cal managed care, fee-for-service Medi-Cal, or any other payment arrangement. 
  • The legislation also specifies additional voluntary submitters, who can opt-in to submit their data to the HPD System.

HPD Program Voluntary Submitters

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. 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.

Upcoming Activities

The Fact Sheet includes anticipated program activities from July 2023 through December 2025.  

Read the full July 2023 Fact Sheet.


  • Begin producing initial analytic reports from the database.
  • Complete rulemaking to certify final claims data collection regulations.
  • Complete rulemaking to establish data access and release regulations.


  • Continue producing analytic reports from the database.
  • Begin accepting data application for non-public data.
  • Submit report to the Legislature with progress on data collection, quality, and completion by March 2024.


  • Continue producing analytic reports and processing applications for non-public data.
  • Begin collecting dental data.
  • Publish the HPD Advisory Committee’s recommendations on how to integrate state public health data functions into the HPD by July 2024.


  • Continue producing analytic reports from the database and processing applications for non-public data.
  • Complete rulemaking to establish non-claims payments data collection regulations.


  • Continue producing analytic reports from the database and processing applications for non-public data.
  • Begin collection of non-claims payment data.


Contact HPD at hpd@hcai.ca.gov with any questions.

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