Kepa, Changing the version number of the Addenda would require additional steps within the X12N process. We cannot just "rename" the version and proceed.
Cathy Sheppard Co-chair X12N TG4 ----- Original Message ----- From: "Kepa Zubeldia" <[EMAIL PROTECTED]> To: "Larry Watkins" <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]>; "Stanley Nachimson" <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]> Cc: <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]> Sent: Monday, April 15, 2002 9:56 AM Subject: Re: NPRM for implementation of Addenda > Larry, > > As you know that is the reason why Claredi has not come out with the Addenda > edits yet. It would be pretty confusing to have more than one version of > the Addenda. > > But here is a thought... The pre-NPRM version of the Addenda is > labeled with A1 (as in 004010X098A1). What if the version after the > final rule is labeled with something else, like "A" or "A2" ? In that case > we could distinguish between the two versions, in case there are changes > during the comment period of the NPRM. > > This would allow people to start working on the Addenda version today, and > make whatever final adjustments are necessary once the final rule is > published. And still keep the two versions separate. > > Is that something the DSMOs would do? Maria, are you there? > > Kepa > > > > > On Monday 15 April 2002 10:42 am, Larry Watkins wrote: > > The one catch with implementing the Addenda today is that it has not yet > > gone through the NPRM comment period, and therefore are not yet final. > > This comment period could mean there will be changes to the Addenda, > > although the DSMOs are committed to as few changes as possible (preferably > > none). > > > > Larry Watkins > > Co-Chair, ASC X12N Health Care Task Group > > Vice President & COO, Claredi Corporation > > Office: (801) 444-0339 x204 > > Fax: (770) 419-5295 > > Mobile: (770) 331-1898 > > e-Mail: [EMAIL PROTECTED] > > > > > > -----Original Message----- > > From: Kepa Zubeldia [mailto:[EMAIL PROTECTED]] > > Sent: Monday, April 15, 2002 10:11 AM > > To: [EMAIL PROTECTED]; Stanley Nachimson; [EMAIL PROTECTED]; > > [EMAIL PROTECTED]; [EMAIL PROTECTED] > > Cc: [EMAIL PROTECTED] > > Subject: Re: NPRM for implementation of Addenda > > > > > > Stanley, > > > > Thanks for the follow up and the clarification. I sure hope nobody forgets > > to file for the extension. > > > > What if the Addenda final rule comes out later than February 16, 2003? > > There > > is still some hope. Let me explain. The fact that the Secretary must give > > at least 180 days for the Addenda to become "the" HIPAA standard does not > > mean that the industry cannot implement the Addenda in less than 180 days. > > In fact, if the industry implements the addenda early (as a volunteer > > private > > format) then we don't need the 180 days. As long as the industry > > implements > > the Addenda NOW, *AND* the effective date for the Addenda Final Rule is not > > after October 16, 2003, we are OK. > > > > The trick for that to work is that when the Addenda Final Rule comes out it > > should allow the Addenda version to be a valid HIPAA standard along the May > > 2000 version for the 6 month transition. Both versions valid as HIPAA > > standard during those six months. If that is not the case, and the Addenda > > instantaneously REPLACES the May 2000 version at the end of the 180 days, > > then we will be in trouble. I sure hope there is this sort of "overlap" > > when > > new versions are going to be adopted. > > > > So, assuming there is "overlap" of 6 months for the two versions, as long > > as there is no more than a little slippage in the dates, and everybody > > files for > > the extension, we should be OK in implementing the Addenda TODAY. > > > > All of this got me thinking about what we need to do at Claredi concerning > > the Addenda version. We have been waiting for the Final Rule to come out, > > but now I think we need to accelerate the Claredi schedule... > > > > Kepa > > > > On Monday 15 April 2002 06:39 am, Stanley Nachimson wrote: > > > 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. 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