Kepa, Just to add my two-cents' worth....I totally agree with your recommendation re version control of the draft addenda vs the final approved addenda. Without such versioning, it will be a nightmare to know what to implement and how to manage it. This is basic systems change management 101.
Rachel -----Original Message----- From: Kepa Zubeldia [mailto:[EMAIL PROTECTED]] Sent: Monday, April 15, 2002 11:58 PM To: [EMAIL PROTECTED]; [EMAIL PROTECTED] Cc: [EMAIL PROTECTED]; [EMAIL PROTECTED]; [EMAIL PROTECTED]; [EMAIL PROTECTED]; [EMAIL PROTECTED]; [EMAIL PROTECTED]; [EMAIL PROTECTED]; [EMAIL PROTECTED] Subject: Re: NPRM for implementation of Addenda Maria, Cathy, Larry, So, if the "A1" suffix is not going to change, and there could be changes to the Draft Addenda as a result of the comment period (and most likely there will be changes) there goes the version control out the window. Does the A1 suffix represent the Draft Addenda as we know it today AND also the final Addenda as modified by the comment period changes? Unless there is a clear distinction of the two versions, nobody will be confident/comfortable to implement the Draft Addenda as they are today, and we will have to wait until the Jello sets and the final version gets published. Maria, I recognize that the Addenda that we have from October 31, 2002 is just a DRAFT subject to change. But the fact is that, with nothing better, some people are implementing from the Draft, as time is running out. And if the target is going to move on them, then the new target ought to have a different suffix. At least, if the Draft Addenda had its own version number, we could implement it even temporarily as a proprietary version, and then upgrade it when the final version comes out. But if the Draft does not have its own version number, we will never know which one we are talking about, so we really cannot implement the Draft version. And, since this list is a WEDI list, let me remind everybody that the WEDI board has officially recommended to skip the May2000 version of the guides and go straight to the Addenda version. And since all we have is a DRAFT Addenda version, they probably meant to go for the Draft Addenda as the target for implementation. One more item for discussion in the next X12 meeting. My recommendation is that the A1 suffix should refer to the draft version, and die with it. When the final comes out, instead of A1 it should have something else as the suffix. If there are no changes, fine, you don't even need to change the suffix for that transaction. But is there is even one change, the suffix must be changed. This is a critical issue that X12, the DSMOs, and HHS need to address right away! Just my $.02 worth. Kepa PS: My time line did not include much time for the DSMO/X12 review of the comments from the NPRM. I hope that will not take too long... On Monday 15 April 2002 10:10 pm, [EMAIL PROTECTED] wrote: > Kepa > > I'm actually pleased to say that I haven't been out there for the past few > days, I've been on vacation. There's obviously been quite a discussion > taking place about the addenda - I saw your earlier e-mail and sent a > reply. Having read Larry and Cathy's e-mails just now I'd like to echo a > few things. As Larry points out, the DSMOs have no role in making a > decision about the version numbers - that's an X12 thing. Another really > important point that Larry made was in reference to the addenda being > proposed/pre-final rule. The importance of understanding that is basically > the theme of my earlier reply. And Cathy makes an observation that I was > always thinking as well (although I never actually heard it discussed) - I > just assumed that this comment period process would be handled in X12 in a > similar manner as its predecessor was, i.e. the version (A1) wouldn't > necessarily change after the comment period closed and any changes were > made to the final. As Cathy indicated, we provided new IGs reflective of > changes made in the comment period but the version remained. I guess I > thought this would be the same... > > > Maria > > > > > > > > > Kepa Zubeldia <[EMAIL PROTECTED]> on 04/15/2002 11:56:34 AM > > Please respond to <[EMAIL PROTECTED]> > To: "Larry Watkins" <[EMAIL PROTECTED]>, > <[EMAIL PROTECTED]>, "Stanley Nachimson" > <[EMAIL PROTECTED]>, <[EMAIL PROTECTED]>, > <[EMAIL PROTECTED]>, <[EMAIL PROTECTED]> > cc: <[EMAIL PROTECTED]>, [EMAIL PROTECTED] > 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, 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. ********************************************************************** 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.
