Cathy, Any thoughts on how we are going to distinguish the version prior to the Final Rule as opposed to the version after the final rule if there were any changes made to these documents during the comment period?
Kepa On Monday 15 April 2002 12:27 pm, Cathy Sheppard wrote: > 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. > > 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. 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