Health Care Payments Data (HPD) Frequently Asked Questions
General Information
1. 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.
2. 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.
3. 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.
4. Who can access HPD data?
The public can access HPD data through publicly available information, including data products and analytics 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 about how to access non-public data. Individual patient-level data is exempt from the disclosure requirements of the California Public Records Act.
5. 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. Health and Safety Code (HSC) sections 127671 to 127674.1 establish 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 laborers. The Data Release Committee makes recommendations to HCAI on the 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.
6. What is the budget and funding source for the HPD Program?
The HPD System is a statewide resource and requires investment to operate. HCAI was appropriated $60 million in General Fund money from the 2018-2019 Budget Act (Chapter 23, Statutes of 2019) to fund the implementation and operation of the HPD Program. That funding source expired in June of 2025.
The HPD Program was authorized one year of funding in the 2025-2026 Budget Act, sourced from the Health Care Payments Data Fund, the Managed Care Administrative Fines and Penalties Fund, the Pharmacy Benefit Manager Fund, and federal funding through the Medi-Cal program. HCAI 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 HPD Program for 2026 and beyond.
7. 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. 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. It is anticipated that data will be submitted annually. OHCA released the Baseline Report on health care spending in California in June 2025.
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.
8. 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. HPD data is 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.
9. Is the 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, DHCS, and CMS 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.
10. How can data submitters provide input on future updates to the APCD-CDLTM?
The All-Payer Claims Database Common Data Layout (APCD-CDLTM) has been developed by the National Association of Health Data Organizations (NAHDO) and the APCD Council to harmonize claims collection efforts across states and reduce the burden of data submission. This national effort has prioritized, and continues to incorporate input from various stakeholders, including health plans. You can find out more information about the data maintenance request process on the APCD Council website. HCAI will solicit feedback from California health and dental plans about the APCD-CDLTM and can facilitate sharing consolidated feedback to the APCD Council to represent the state’s unique and diverse healthcare landscape. Email hpd@hcai.ca.gov for more information.
Registration for Data Submission
1. What is my Payer Code (data element codes CDLHD003 and CDLTR003)?
The Payer Code will be supplied upon registering to submit data to the HPD Program. A list of approved Payer Codes will be provided to submitters prior to reporting data to the HPD initiative, and submitters must include the Payer Code as part of each reported submission. However, if a submitter reports data on behalf of more than one plan, they should leave the Payer Code in the Header and Trailer records of each file null.
2. What is my submitter code (data elements CDLHD002 and CDLTR002)?
The Submitter Code will be assigned to each submitting organization as part of the Submitter Registration process. The same submitting entity may report data under more than one Submitter Code if a submitting entity needs to report claims adjudicated under different methods/systems in separate or if a submitting entity finds that mapping separate source systems per file type is easier to do so under separate mappings (e.g., one Submitter Code provided for mapping HMO data, another Submitter Code provided for mapping PPO data, etc.).
3. Where can I find out more about how to register for HPD data submission?
This information is included in the California Code of Regulations Section 97330-97334 and in the HPD Reporting Manual v3.0.
For questions regarding the registration process, please contact Onpoint Health Data at hpd-support@onpointhealthdata.org.
Mandatory Data Submission
1. Who is required to submit data to HPD?
- Commercial plans licensed with the Department of Managed Health Care (DMHC) and the California Department of Insurance (CDI), who have greater than the threshold of covered lives defined in the HPD Regulations.
- Public self-insured entities who have greater than the threshold of covered lives defined in the HPD Regulations.
- Qualified Health Plans offered by the California Health Benefit Exchange (Covered CA) is a mandatory submitter regardless of the threshold.
For more information about what entities are required to submit to the HPD, please refer to California Code of Regulation Sections 97310 and 97314.
2. Is it required that submitters report all claims for services provided in California or all claims for Californians, even if they were provided out of state?
HPD requires data for California residents, regardless of where the services were provided. For more information, please refer to California Code of Regulations Section 97342.
3. What type of HPD data is required to be submitted?
Submitters are required to send Medical Claims, Pharmacy Claims, Dental Claims, Medical Eligibility, and Provider Data. Beginning on March 25, 2025, submitters will be required to submit NCP data, including Capitation Files, Annual Payment Files, and Pharmacy Rebate Files. The testing period for NCP data collection will begin on September 1, 2025. Please see the NCP Fact Sheet for additional information.
4. How often will submitters need to provide data?
- Ongoing data submission for Member Eligibility, Medical Claims, Pharmacy Claims, Dental Claims, Provider data, and Capitation Files is on a monthly basis. Regular monthly reporting for Capitation Files will begin for the month of August 2026 on October 1, 2026.
- Ongoing data submission for Annual Payment Files and Pharmacy Rebate Files is on an annual basis beginning for the calendar year of 2025 on September 30, 2026.
5. What are the registration and testing requirements for historical NCP data files?
Mandatory plans and delegated submitters who will be submitting NCP data files are required to update their 2025 Plan Registrations or 2025 Submitter Registrations before testing can begin. After updating their registration, plans and delegated submitters are required to submit at least one test file by September 1, 2025, through the data portal for each historical NCP data file type. Plans and delegated submitters must successfully complete testing for each historical NCP data file type they will submit.
For more information on testing requirements, refer to Section 4.2 of the HPD Data Submission Guide version 3.0 or contact Onpoint Health Data at hpd-support@onpointhealthdata.org.
Please see the NCP Fact Sheet for additional information.
6. Other than the statute, what other documentation or data specifications are available for submitters to review?
- The HPD Data Collection regulations became effective in December 2021, and data collection began in 2022. The regulations describe how HCAI is implementing the statute and are continuously maintained to ensure submitters are following the most up-to-date requirements when submitting data to the HPD.
- The Data Submission Guide version 3.0 describes the requirements of the datasets and has been incorporated in the HPD Data Collection regulations.
- The HPD Reporting Manual version 3.0 consists of discussion and comments related to the implementation of HPD regulations.
- The NCP Data Layout – Submissions Scenarios document provides fictitious examples of data to provide data submission scenarios for NCP data files.
7. Will a submitter be able to apply for a temporary data variance if they are unable to comply with the current Data Submission Guide?
Yes. The process for requesting a temporary data variance is included in California Code of Regulations Section 97370. A data variance is intended to allow a submitter relief from specific requirements for a limited time while they enhance their data collection processes. Information on how to request a data variance is also included in the HPD Reporting Manual version 3.0.
8. What type of edits will HPD apply to submitted files, and what happens if there are errors in the submission?
The HPD System will initially compare submitted data files to the data element definitions in the APCD-CDL™ and the NCP Data LayoutTM with regard to data element position, field length, and defined data type. The system will then validate the completeness of required or situational data elements as defined in the Data Submission Guide (DSG). Further validations that will be applied, including coding standards, distribution characteristics of a given field, and relationships between data elements.
A submitted file may be rejected upon submission if the formatting does not meet the requirements set forth in the DSG. When this happens, the submitter will be notified. Rejection is at the file level not the record level. If a file is rejected, the submitter must correct the file and resubmit. In addition, a file may be accepted through formatting and then fail validation checks, which may require a file to be resubmitted.
9. Do we need to include Dental ONLY membership in the Member Eligibility file?
Submission of dental claims data is not required until the 2024 timeframe. However, Please refer to the HPD Reporting Manual version 3.0 regarding submitting dental claims data.
Dental services submitted on an 837 P/I that are covered under a member’s medical benefits are expected and should be reported within the medical claim file. These types of claims include services that are deemed “medically necessary” and would not include data elements such as tooth number or tooth surface, with CDT codes reported in the procedure code field (CDLMC088).
10. What is the HCAI size limitation on the monthly, annual, and historical files?
The preference is that files would not exceed 10 million records per file. If a submitter intends to submit a monthly file larger than 10 million records, please reach out to the Onpoint Support Team hpd-support@onpointhealthdata.org.
11. What is the file naming convention that needs to be followed for each of the files?
Per the HPD Reporting Manual version 3.0, the file naming convention is at the discretion of the submitter, but submitters are encouraged to include a submission date/version number in the file name reported so as to better identify multiple iterations of the same file type and reporting period.
12. When are the historical and production HPD data files due?
For dental data files:
- Dental plans will complete historical data submission for the period of June 29, 2017, through December 2021 by October 31, 2024.
- Dental plans will begin ongoing monthly data submission for November 2024, due on January 1, 2025.
- Dental plans will submit all remaining data for the period between January 2022 and October 2024 by February 1, 2025.
For NCP data files:
- Submitters will be required to send Capitation Files starting with historical data (June 29, 2017, through July 31, 2026) by September 1, 2026. Submitters will send production 2026 monthly Capitation Files beginning with the month of August by October 1, 2026.
- Submitters will be required to send Annual Payment Files and Pharmacy Rebate Files starting with historical data (June 29, 2017, through December 31, 2024) by July 31, 2026. Regular annual reporting of Annual Payment Files and Pharmacy Rebate Files will begin for the calendar year of 2025, to be submitted by September 30, 2026.
For more information, please refer to California Code of Regulations Sections 97350, 97351, 97352, and 97353 and the Data Submission Guide version 3.0.
13. For the historical data submissions, is HCAI expecting one file per year or all this data in one historical file?
Historical data can be provided in monthly, quarterly, or annual increments.
Voluntary Data Submission
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 the federal Employment Retirement Income Security Act of 1974 (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 ERISA to submit data to a state APCD. The decision, Gobeille v. Liberty Mutual Insurance Company, 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).
While private self-insured employers and Taft-Hartley trusts 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.
2. Aren’t CalPERS and other public purchasers also self-funded? Are they required to submit data?
The Gobeille v. Liberty Mutual Insurance Company 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 Data Collection regulations outline the process to become a voluntary submitter.
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 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. Request assistance connecting with your ASO.
Contact
Contact HPD at hpd@hcai.ca.gov with any questions.
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