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MAHI Annual Meeting – Keynote Address

MAHI Annual Meeting – Keynote Address. Catherine Schulten Healthcare Business Development Sybase, Inc. Agenda. HIPAA Implementation Guide Addenda ASCA (Administrative Simplification Compliance Act) and it’s impact on the industry Vendor Readiness and other stuff Q&A. HIPAA Expertise.

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MAHI Annual Meeting – Keynote Address

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  1. MAHI Annual Meeting – Keynote Address Catherine Schulten Healthcare Business Development Sybase, Inc.

  2. Agenda • HIPAA Implementation Guide Addenda • ASCA (Administrative Simplification Compliance Act) and it’s impact on the industry • Vendor Readiness and other stuff • Q&A

  3. HIPAA Expertise • AFEHCT, co-chair ASPIRE workgroup (CMS 1500 and UB92 print image gap analysis/demonstration project) • HL7 membership, ASIG workgroup (claim attachments) • X12N membership, TG3 WG3 (HIPAA Implementation and Modeling) • Testified on HIPAA issues to NCVHS • WEDI Board of Directors ’02-’04, Co-chair Emerging Technologies, • WEDI SNIP, Co-chair Translations sub-workgroup • NCPDP membership • MAHI membership

  4. Alphabet Soup! HHS DSMO’s CMS NCVHS NUCC HL7 WEDI AFEHCT NUBC NCPDP WEDI SNIP X12 DeD MAHI Regional SNIPs

  5. Background on HIPAA Addenda Issue • Each of the X12N Implementation Guides (IG’s) originally published May 2000 and adopted for use under HIPAA have had addenda created for them • Although the addenda are available for download at www.wpc-edi.com, it is important to remember that these addenda are in DRAFT version

  6. Why do we have IG Addendum? • After the publication of the HIPAA IG’s in May ’00, early adopters identified a variety of implementation and interpretation issues with the guides • These issues were brought before X12N and NCVHS for resolution • NCVHS recommended a “fast track” process for the industry to adopt to quickly respond to and resolve the implementation issues in time to meet the original 10/16/02 deadline

  7. Timeline of Events • May ’00 – Version 4010 HIPAA IG’s finalized and available at WPC • Early adopters identify problems (errata and non-implementable “show-stoppers”) • Feb ’01 – Implementation issues brought to NCVHS, “Fast Track” Process established in response to the need to bring resolutions into play prior to 10/16/02 • Feb – Apr ’01 – DSMO’s review “fast track” requests • Apr ’01 – DSMO’s determine which requests are necessary for compliance (show-stoppers) • Summer ’01 – These items given to HHS for their development of NPRM • Summer/Fall ’01 – “Fast track” items incorporated into addenda by WPC, HHS NPRM development process begins • Oct ’01 – Addenda available for review at WPC • 12/27/01 – 1-year extension for HIPAA EDI Transactions compliance approved by Congress and signed by President • Today – NPRM for Addendum still not yet published by HHS. Latest estimate given is late March 2002.

  8. Federal Rule Making Process Once the Federal Rule Making Process begins there is a set of steps that must be accommodated: • NPRM Published • 60-day public comment period begins • Comments reviewed by HHS and DSMO’s • Comments may be forwarded to appropriate workgroups within X12N is DSMO’s deem necessary (X12N is the subject matter experts for the addendums) Timeframe for this step is unknown • All comments addressed and FINAL RULE published • 60-day Congressional review period begins • Final Rule for HIPAA Addendum is Final • 6-month time-frame to institute addendum

  9. 270/271 276/277 278 820 834 835 837P 837I 837D 004010X092A1 004010X093A1 004010X094A1 004010X061A1 004010X095A1 004010X091A1 004010X098A1 004010X096A1 004010X097A1 Addendum Guide Names

  10. The issues • Deadline for implementation (10/16/02 v. 10/16/03) • Which version of the IG’s to implement (4010?, 4010A1 prior to or after Final Rule?) • What are your Trading Partners doing? • What about NPRM’s for J-code/NDC and Taxonomy issues? HIPAA Addenda

  11. What should we do? • Technically if a covered entity wants to be in compliance by 10/16/2002 and not file for an extension they will have to implement based on the May 2000 specifications. This would mean use of the NDC codes for drugs and also the requirement for provider taxonomy code • CMS’s approach will be the “hybrid” – implementing the May 2000 specifications with some exceptions and filing an extension in order to have time to implement 278’s and 820

  12. WEDI SNIP’s recommendation • Apply for the extension • Work toward implementing the 4010A1 version of the IG’s • Consider that the NPRM relaxing the requirement for NDC and Taxonomy codes will soon be published

  13. ASCA – Administrative Simplification Compliance Act • ASCA provides a 1-year extension (from 10/16/02 to 10/16/03) for achieving compliance with Transaction and Code Set Standards Final Rule • Was developed and approved independently from any considerations concerning the IG Addenda • Medicare requirement for electronic claim filing for organizations of a certain size

  14. ASCA Info • http://www.hcfa.gov/hipaa/hipaahm.htm • Model form for submitting to HHS will be published soon, a Draft copy was previewed last week at WEDI SNIP and can be viewed at www.wedi.org • Goal was to provide an easy-to-understand form and companion document that the industry could submit

  15. ASCA Info • CMS requests that organizations wait until the Model Form is available on their website and submit electronically • Avoid submitting the form on paper • Encourage an official corporate designee to sign and submit the form

  16. Vendor Readiness • Many Covered Entities are relying heavily upon their vendors to “make” them “HIPAA compliant” • Readiness surveys, like Y2K, are being sent to vendors inquiring about their state of compliance • Concern that vendors aren’t being forthcoming and may not be able to support their customers

  17. Vendor Readiness • “Is your software HIPAA compliant?”  • “Provide a list of all products you have sold us and their HIPAA readiness information”   • “Do you warrant that as of the HIPAA Effective Date that the software complies in all material respects with HIPAA?” • “System must be HIPAA compliant and contractually warranted as such. It must also have set HIPAA compliance maintenance fees going forward. Time frame limitations for any enhancements due to HIPAA compliance must be addressed when these are released by HIPAA”   • ”We assume that the release containing changes to comply with HIPAA will be included as part of the normal support fees we have paid. If not, please explain.” •   “At what release level do you expect to comply with HIPAA and when will this release be generally available?”  • “Are you designing or redesigning your systems to be compliant with HIPAA Security regulations?”

  18. Other Stuff • CMS1500 & UB92 paper claim formats vs. HIPAA-compliant 837’s • ASPIRE (Administrative Simplification Print Image Research Effort) • www.afehct.org • White paper published at WEDI SNIP • Phase II beginning soon

  19. Other stuff • Claim Attachments • HL7 clinical data imbedded into an X12 transaction • Clinical data needed to support payment of a claim (Ambulance, Rehab, Emergency Dept, Clinical Reports, Lab Reports, Medications)

  20. Other stuff • Regional outreach is working! • Greater turnout at regional SNIP events than ever expected • Less distance to travel • 1-day or ½ day events • Low cost • Your trading partners are in the room • “looking for solutions” v. “developing solutions”

  21. Questions and Answers Thank you! Catherine Schulten

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