Kepa/Stanley
I agree with most of what's been said here but would also like to offer one
word of caution...the addenda, as they appear today on WPC are proposed,
not final changes to the IG's. People need to understand this before they
make any decisions and I'm not sure everyone does. Something tells me
there are going to be comments that will result in changes to at least some
of the proposed addenda. People need to understand this as they decide
whether to go full steam ahead or not...
Having said that, might I suggest that covered entities consider a few
things right now:
1. Look at the addenda. There are a significant number of entities that
don't even know it exists so looking at it and assessing your position is
even a step in the right direction. Then decide whether or not there are
changes being proposed that will affect you / your business. If so, take
an educated guess (or seek assistance in doing so) as to whether these are
proposed changes that are likely to change. Some of these changes are more
controversial than others and some affect many more entities than others.
If there are proposed changes that you determine have a high probability of
changing as a result of the comment period you have to make an informed
decision as to whether you should implement it "as proposed" (e.g.
implement now) or wait until the final.
2. If you determine that X number of proposed changes will affect you and
of those Y number are not likely to change after the comment period, it
might be prudent to proceed with implementing them (again, after you've
done some analysis). If you think that some of them are likely to change
you might want to consider the effort involved with implementing now and
then re-working once the final is out.
Basically, if entities can reduce the universe of changes (as currently
proposed) they'll have to deal with first, then determine which of those
are probably "safe" to implement now, that might be a more cautious
approach. It will also take a little more work now, but if it saves you
re-work on the backend it may be worth it. I'm not suggesting this
approach is appropriate for everyone, obviously people have to determine
that for themselves by assessing their situation.
Now an official DSMO comment...
As for the timeframes and process -- since the DSMO Steering Committee will
be receiving the comments from HHS for review (used to go directly to the
SDO) and forwarding necessary comments on to the SDO, maybe we (DSMO
Steering Committee) can help expedite the turn around of these comments and
therefore get us to a final rule faster. I can assure you that this is our
intention and we have been planning (as a committee) on how to quickly and
effectively review and provide feedback on the comments.
Maria
Maria Ward
Chair, DSMO Steering Committee
PriceWaterhouseCoopers
Healthcare Consulting Practice
312.298.2586
"Stanley Nachimson" <[EMAIL PROTECTED]> on 04/15/2002 07:39:16 AM
To: <[EMAIL PROTECTED]>, <[EMAIL PROTECTED]>,
<[EMAIL PROTECTED]>, <[EMAIL PROTECTED]>, <[EMAIL PROTECTED]>
cc: <[EMAIL PROTECTED]>
Subject: Re: NPRM for implementation of Addenda
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, go to:
http://snip.wedi.org/unsubscribe.cfm?listusiness
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.
----------------------------------------------------------------
The information transmitted is intended only for the person or entity to
which it is addressed and may contain confidential and/or privileged
material. Any review, retransmission, dissemination or other use of, or
taking of any action in reliance upon, this information by persons or
entities other than the intended recipient is prohibited. If you received
this in error, please contact the sender and delete the material from any
computer.
**********************************************************************
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.
