Kepa, you are basically correct. Any entity that applies for an extension has until
Oct 16, 2003 to become compliant, therefore they can use whatever format they want
until that time. Hopefully, the addenda will be the required set of standards on Oct
16, 2003.
However, entities that do not apply for the extension must be able to use the current
set of standards on Oct 16, 2002 and after; not the addenda.
(And I hope we meet the timelines noted in your email).
Stanley Nachimson
Office of Information Services, CMS
410-786-6153
>>> Kepa Zubeldia <[EMAIL PROTECTED]> 04/13/02 10:18PM >>>
Chris,
Here is the situation as I understand it. Stanley, please correct me where I
am wrong.
The Addenda version of the guides was published on October 31. The NPRM in which the
Secretary will propose to adopt the Addenda as HIPAA standards has
not been published yet. From Dave's email the other day, we know that the NPRM was
sent to OMB for their 90 day review on or about March 23. If the OMB takes 90 days
(the have said they will not take that long) then we should
see the publication of the Addenda NPRM around the end of June. Sooner if they don't
take the full 90 days.
Then there will be 30 days for comments. End of July. Perhaps sooner.
Then HHS needs to review the comments. This could get lengthy if there are thousands
of comments. Lets be an optimist and say that the process takes 3
months (don't laugh, please) and that CMS/HHS takes another month to write the actual
preamble to the final rule. So by the end of November the Final
Rule could be written and ready to go to OMB. Give OMB another 60-90 days, and the
Final Rule could be published int he Federal Register by February 16.
Then there is 60 days for congressional review before the final rule on the Addenda
becomes effective on April 16, 2003.
And, according to HIPAA, the Secretary can give "no less" than 180 days
before a change in HIPAA implementation guides becomes the law of the land. So, from
April 16, we go to October 16, 2003 before the Addenda guides become
the HIPAA guides that everyone must implement. At that point, the May 2000 version of
the guides becomes non-standard.
Well, I was trying to be an optimist in my time frames. If these time frames
slip by even one month, we are in deep doodoo. It seems to me like we may not be able
to implement the Addenda without implementing the May 2000
version first. We are running out of time!
However, the pragmatist inside of me is starting to boil and overflow...
What if you implement the Addenda version NOW?!
Since it looks like everybody is going to have to file for the ASCA
extension, you will have until October 16, 2003 to comply. In the meantime you can
use any proprietary EDI format of your liking. Including the Addenda
version of the guides!
Yes, that is right. If you want, you can start using the Addenda guides
effective immediately. Until it becomes a "de jure" HIPAA standard, it can be
considered just another "proprietary" EDI format. You don't have to wait
for the Secretary's blessing to start using the Addenda version.
In fact, the WEDI board has recommended that people skip the May 2000 version
and move directly to implement the Addenda version. Let's hope we don't get
caught in a train wreck.
So, in answering the question "what is the earliest date that you can
implement the Addenda guides?" I would say the answer is TODAY!
Now, lay back and watch the flames.
Kepa
On Saturday 13 April 2002 12:24 pm, Christopher J. Feahr, OD wrote:
> Dave,
> I'm still a little confused regarding the earliest date at which CEs can
> actually implement the addenda version of the IGs in their business
> applications. Is this particular "addenda" in any way "special" in that
> regard... since this is considered to be the initial ("fast-track") "course
> correction" permitted in the first year after the rules initial
> publication? On what schedule will they be able to implement futire IG
> changes?
>
> It will be one matter (and not a simple one) for CEs to maintain access to
> all these different code set versions over the years... because the version
> at the time of initial service will be the "legal" one for any transaction
> (right?). But having to maintain systems programmed to various versions of
> the IGs sounds impossible. Are we going to attempt to maintain a degree of
> "backward compatibility" in the new IG versions?
>
> -Chris
>
> At 09:09 PM 4/7/02 -0700, David A. Feinberg, C.D.P. wrote:
> >Deepan,
> >
> >X12N's Addenda for their HIPAA-adopted Implementation Guides were, indeed,
> >posted to the Washington Publishing Company (X12N's publisher) website
> >(<http://www.wpc-edi.com/hipaa>www.wpc-edi.com/hipaa) in late October,
> > 2001.
> >
> >These Addenda are intended for reference in the Federal Government's
> >forthcoming Notice of Proposed Rule Making (NPRM) regarding potential
> >changes to the HIPAA Electronic Transactions regulation. This NPRM has
> >not yet been published in the Federal Register.
> >
> >Once the Addenda NPRM is published, there are still a number of steps that
> >must be completed before the Addenda can be considered final and required
> >for implementation under an additional final HIPAA Electronic Transactions
> >regulation. Completing these steps will likely take many more months!
> >
> >I hope this short note helps clarify a bit what is a quite lengthy
> > process.
> >
> > Dave Feinberg
> > Co-Chair, HIPAA Implementation Work Group
> > Insurance Subcommittee (X12N)
> > Accredited Standards Committee X12
> > Voting Member, HL7 and X12
> > Rensis Corporation [A Consulting Company]
> > 206-617-1717
> >
> ><mailto:[EMAIL PROTECTED]>[EMAIL PROTECTED]
> >----- Original Message -----
>
> From: <mailto:[EMAIL PROTECTED]>Deepan Vashi
>
> >To: <mailto:[EMAIL PROTECTED]>[EMAIL PROTECTED] ;
> ><mailto:[EMAIL PROTECTED]>[EMAIL PROTECTED]
> >Sent: Saturday, April 06, 2002 5:05 AM
> >Subject: NPRM for implementation of Addenda
> >
> >Hi everyone,
> >
> >Draft NPRM for Addenda to Implementation Guide (IG) for all transaction
> >sets (270,271,835,837,276,277,278) was released in October 2001.
> >
> >Can anyone suggest, if this NPRM has been cleared and changes suggested in
> >Addenda are required to be implemented ?
> >
> >Thanks
> >
> >Deepan
To be removed from this list, go to:
http://snip.wedi.org/unsubscribe.cfm?list=business
and enter your email address.
The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions
on this listserv therefore represent the views of the individual participants, and do
not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If
you wish to receive an official opinion, post your question to the WEDI SNIP Issues
Database at http://snip.wedi.org/tracking/.
Posting of advertisements or other commercial use of this listserv is specifically
prohibited.
**********************************************************************
To be removed from this list, send a message to: [EMAIL PROTECTED]
Please note that it may take up to 72 hours to process your request.
=====================================================The WEDI SNIP listserv to which
you are subscribed is not moderated. The discussions on this listserv therefore
represent the views of the individual participants, and do not necessarily represent
the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an
official opinion, post your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/.
Posting of advertisements or other commercial use of this listserv is specifically
prohibited.
