TO: ALL Happy New Year!!!
For those interested with healthcare-related projects for IT and E-Commerce, please review the following messages. Thanks, David Paraiso http://www.edi-info-center.com [EMAIL PROTECTED] Hotline: (800) 949-9278 FAX: (626) 918-6115 ----- Original Message ----- From: Jeffrey Young To: HIPAAlive Discussion List Sent: Thursday, January 03, 2002 10:45 PM Subject: [hipaalive] RE: Transactions Compliance Extension *** HIPAAlive! From Phoenix Health Systems/HIPAAdvisory.com *** David S.: Medicaid and Medicare are both federally funded health care programs. Medicaid is operated by each state, while Medicare is operated directly by CMS. The State of Tennessee is the "TPA (third party administrator)" if you will, for Medicaid recipients in that state. As the largest payer in the US (CMS as the owner of Medicaid and Medicare covers almost 40 million people because of Medicaid's role as payer of last resort), the HIPAA regs specifically name Medicare and Medicaid as covered entities. The agency that operates the Medicaid program varies by state (in OR for example, it is the Health Services Division of the Department of Human Services). David F.: You're right. The dominoes are more like an avalanche when you look at the numbers: 650 Indemnity Carriers 1500 HMOS 750 TPAs 50,000 Self administered plans 5,700 acute care hospitals 18,400 skilled nursing facilities 9,000 hospices 22,000 residential mental health/substance abuse faciliities 44,000 pharmacies 9,500 medical labs 7,900 dental labs 112,000 DME providers 214,000 physician practices 120,000 dental practices 18,000 Optometrists 50,000 other practices Total count: approximately 683,400 organizations that in theory could apply for an extension after they've 1) assessed their compliance 2) developed an implementation plan and 3) determined they can't make the date. If survey data holds true, only 15% of these organizations have actually started addressing their compliance. That leaves 450K plus who have those steps to complete and won't be ready to file an application tomorrow if they had to. They are about 90 days behind everybody else who have achieved that step. If just five percent (and this is a very conservative number) of these organizations apply for extensions prior to October 16th, that would be 34,000 extensions to be reviewed and approved by HHS. However, the format for an extension won't be available until mid-March. That leaves only 8 months to process all the extension applications. In an average distribution, that's over 4K per month and 200 applications a day every business day until the deadline. If you take some of the estimates that say more than half of all major payors and institutional providers can't make the deadline, that number could reach 100K depending on whether owned and affiliated organizations file as a single covered entity. HHS is not equipped to deal with that kind of volume in either case given all the reviewers defined by ACSA. It doesn't make an extension a very viable option, but reinforces that the combination of using clearinghouses to translate formats AND changing key business processes and rules to match the HIPAA standards, are the most likely routes to achieve compliance. Funny thing is that X12N is an industry represented committee and payers are having as hard a time getting this under control as the providers. Just from my exposure to a select organizations, I'm learning that more education on the structure of the transaction and the definition of its elements is needed to truly figure out what the real gaps are. Just a thought. Jeffrey Young BEST Consulting 700 NE Multnomah Suite 1100 Portland, OR 97232 Telephone: (503) 236-5787 -----Original Message----- From: David A. Feinberg, C.D.P. Sent: Thursday, January 03, 2002 8:42 PM To: HIPAAlive Discussion List Subject: [hipaalive] RE: Transactions Compliance Extension *** HIPAAlive! From Phoenix Health Systems/HIPAAdvisory.com *** >From section 2 of the Administrative Simplification Compliance Act (ASCA, also known as HR3323): "... a health care provider, health plan (other than a small health plan), or a health care clearinghouse shall not be considered to be in noncompliance with the" electronic transactions and code sets regulations "only if, before October 16, 2002, the person [i.e., the provider, health plan or clearinghouse] submits ... a plan of how the person will come into compliance ... not later than October 16, 2003." But all of us need to continue to keep in mind that non-standard transactions translated in to or out of standard transactions by a HIPAA clearinghouse are compliant. [Beyond this, though, I, too, am beginning to smell the onset of a big game of falling dominoes :-).] Dave Feinberg Rensis Corporation [A Consulting Company] 206-617-1717 _ Philippine Linux Users Group. Web site and archives at http://plug.linux.org.ph To leave: send "unsubscribe" in the body to [EMAIL PROTECTED] To subscribe to the Linux Newbies' List: send "subscribe" in the body to [EMAIL PROTECTED]
