Folks,
 
Now that we're wading deeper into the 276/277, more questions are surfacing. Hopefully, someone monitoring this listserv can help us address them.
 
I'll post more as I remember them, but the immediate question we have is regarding the information we send back to the originator of the 276 inquiry.
 
There is a large possibility that we will be unable to precisely identify the Provider specified in the 276, since all we have to go on is a name and TIN. This being the case, it is possible that we may find multiple claims that match the information given. When this happens, the 276/277 IG indicates that we should return the status of all claims we find that match the inquiry. But this raises questions about privacy. Our impression is that the IGs are written strictly from a technical perspective, with no consideration of security and privacy concerns. If we send back status info about all matching claims, without being sure of precisely who the Provider is in the inquiry, are we going to be violating some other piece of HIPAA?
 
On a related note; in the NM1 segment for the Service Provider, NM108 offers an "SV" qualifier, with the note, "When the provider does not have a National Provider ID and Payer has assigned a specific ID number to this provider this code is required." We have assigned such an ID number to each provider in our system. While this would help us "nail down" the provider, one of our claims processing trainers asserts that it is unreasonable to expect a provider to keep track of every unique ID number assigned to them by each of the potentially hundreds of insurance plans they deal with. While the IG appears to give us carte blanche - perhaps even demands, if one gets right down to it - to reject any 276 that comes in without that ID included, folks in our office with significant experience assure us that our assigned ID simply won't show up on the 276. So where does that leave us If we accept the 276 without that ID, since we have, indeed, assigned it, then we are accepting a non-compliant transaction, since the note says that it is "required." But it seems that we will be rejecting 100% of the inquiries we receive, if we stubbornly insist on adhering strictly to the rules.
 
Any thoughts on either of these issues?
 
Hal Scoggins
SBPA Systems, Inc.
(281) 679-7272 x116


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