We are planning to use the NTE segment in the X156 Reporting guide, but
with some controls. Since the Race code already has a designated home in
the standard, we think that should be the place where is it consistently
reported. Below is an excerpt from the Front Matter, which is under
development, for the X156 guide about the use of the free formed fields
(NTE and K3) used in the 837 standard. We would not like the use of the
NTE or the K3 segments circumvent the intent of using a standard in the
first place. Comments on the language below is welcomed.
NTE and K3 Segments
The use of the NTE and the K3 segments segment in this implementation guide
is to accommodate legislated state data requirements that are not supported
by the current 837 claim/encounter standard. Appropriate use of the NTE
and K3 segments is to define data requirements necessary to comply with
local, state, or federal statutes in a timely manner. The NTE and K3
segments is are intended to report data elements only supported by
submitter information systems. The intent of the NTE and K3 segments is to
accommodate emergency state legislative requirements that are not
accommodated by the current X12 standards.
Any use of free text data in these segments is strongly discouraged. Within
the free text data elements in each of these segments (NTE02 DE 352 and
K301 DE 449), users should make all attempts to use formatted codified
data. Communication of the non-standard data requirements in these
segments to information sources is the responsibility of the governmental
agency responding to the emergency data need.
The NTE segment would be used, rather than the K3 segment, if the
information needs to be qualified to insure proper processing of that data.
----- Forwarded by Robert A. Davis/BPSM/ISHSG/DIVADMIN/DOH on 04/26/2002
01:04 PM -----
"Barton, Joe"
<[EMAIL PROTECTED] To: "'Robert A. Davis'"
<[EMAIL PROTECTED]>
gov> cc:
Subject: RE: States' roles in HIPAA IG
vs. X12 Compliance
04/26/2002 12:08
PM
One segment I have run across in the 837p is the NTE segment. We intend to
use this for information not used in any other segments. Since there can be
multiple NTE segments possible. I have identified which segment contains
what by the use of a NTE segment number, and relevant data in a fixed width
format in the NTE03 comments area. I suppose the Race code, primary
language, etc can be passed here, but in earlier discussions, this method
had not brought up red flags.
-----Original Message-----
From: Robert A. Davis [mailto:[EMAIL PROTECTED]]
Sent: Friday, April 26, 2002 6:29 AM
To: [EMAIL PROTECTED]
Subject: RE: States' roles in HIPAA IG vs. X12 Compliance
I have been patiently reading the listserve items about this issue before
weighing in. I agree with what Rachel has been saying about the
interpretation of the Situational versus Not Used items. That is always
how I have understood the HIPAA regulations. Because of that through the
work of the Public Health Data Standards Consortium and the National
Association of Health Data Organizations (NAHDO), the Health Care Service
Data Reporting guide (X156) was approved for development by X12N. That
guide is an 837 implementation guide being designed to use the 837 standard
to report what I like to call "what's-wrong-with-you and
how-much-does-it-cost" data to agencies with authorizing legislation as at
least one set of users. For instance in the Institutional Claim guide
(X096 or X141-Addenda Guide), the DMG segment for reporting Race and
Ethnicity is listed at NOT USED. Those data elements are critical to most
state discharge data reporting systems. In the X156 guide they are listed
as SITUATIONAL to allow for the reporting of that information. The X156
implementation guide is being written as an alternative to use the 837
standard rather than force even more proprietary formats to be supported by
the provider community to comply with what is typically state or federal
law for reportable information.
With that said, I would like to go on record to say that writing the X156
implementation guide is my second best option for fulling these required
reporting needs. The best solution in my view is what we have now in NYS
with the UB-92 flat file. The agreement we have with providers and payers
in NYS is that if there is a field or record type that is not needed by a
payer or state agency then that field is IGNORED, BUT NOT REJECTED. What
that means is that we do not need a separate implementation guide to use
the same standard to report state mandated data to the state agency and to
use for billing institutional services. The langauge in HIPAA make this
mulitiple use of the 837 transaction impossible. The X156 guide is being
written because the 837 standard is the appropriate standard to choose for
these reporting requirements, since the data source is typically bound by
HIPAA and must use that standard for their institutional billing. The
X096/X141 guide named under HIPAA would not be sufficient to satisfy these
mandated reporting needs and still be compliant under HIPAA.
If given a chance to vote again, I would vote that the IGNORE, DON't REJECT
axiom be built into HIPAA, but since that is not the case it is all ahead
full steam with the development of the X156 guide for reporting health care
services.
Bob Davis
