I would suggest that concerns of this type be included as comments to the NPRM on the addenda changes. Perhaps SNIP can come up with a recommended transition schedule.
Stanley Nachimson Office of Information Services, CMS 410-786-6153 >>> [EMAIL PROTECTED] 04/15/02 06:30PM >>> Kepa's discussion of the "overlap" of versions raises an interesting point for HIPAA and healthcare. In other industries it's quite common for an industry to adopt the rule of "support the current version and the one version back." This is to allow industry participants to transition to newer versions in a controlled manner. Most certainly health care will require a "change management" technique for version control in the future. And the future is almost upon us with the Addenda. Thus, it's essential that some guidance (or something stronger) be established that addresses change management and version control. It is not feasible, reasonable, nor cost effective to continue to expect the industry to have "drop dead" dates by which the "old version/old stuff" is no longer valid and everyone must fall into line with the "new version" all at once. Rachel Rachel Foerster Principal Rachel Foerster & Associates, Ltd. Professionals in EDI & Electronic Commerce 39432 North Avenue Beach Park, IL 60099 Phone: 847-872-8070 Fax: 847-872-6860 http://www.rfa-edi.com -----Original Message----- From: Kepa Zubeldia [mailto:[EMAIL PROTECTED]] Sent: Monday, April 15, 2002 9:11 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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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.
