Tami,
Based on what I know today, following are the remaining steps
[i.e., I'm skipping all that have occurred thus far] that will be
followed to update the current HIPAA Electronic Transactions rule.
[Note: Some portions of what follows are still being defined /evolved
and may change.]
-- NPRM is published in the Federal Register on 31 May 2002.
-- Public comment period on the NPRM ensues. As of this writing,
we've been informed that this comment period is only thirty
days rather than the typical sixty.
-- DHHS / CMS analyze comments received on the NPRM's.
Technical [as opposed to policy] expertise is solicited from
one or more Designated Standards Maintenance Organizations
(DSMO) as needed.
-- X12N makes any additional, absolutely needed, changes to the
Implementation Guide addenda. We expect there may be a few.
-- X12N officially votes to approve the addenda.
-- X12N completes preparation of the final round of version
004010 Implementation Guides addenda.
-- DHHS / CMS prepare new final Electronic Transactions rules.
-- DHHS / CMS obtain internal Federal Government (primarily
from the Office of Management and Budget) clearance
for the new final rules.
-- New final rules are published in the Federal Register.
-- Anticipated thirty (rather than normal sixty) day Congressional
review period on the final rules occurs.
-- New final rules are adopted; i.e., NOW WE'RE REALLY FINAL!
-- Compliance date [which is actually stated in the published final
rules] for the new regulations, the included-by-reference
amended Implementation Guides, and anything else becomes
effective. This compliance date will be no less than 180 days
after the adoption date.
I hope the above is what you were looking for. Again let me caution
you that some of the above may change, and flow times for some of the
steps are unknowable at this juncture.
Please keep in mind that this is the first time any of us have done
this, so there will be adjustments along the way as all of us work
through the process. And finally, I hope the above helps. Further
questions or comments welcomed.
Dave Feinberg
Rensis Corporation [A Consulting Company]
206-617-1717
[EMAIL PROTECTED]
----- Original Message -----
From: <[EMAIL PROTECTED]>
To: "David A. Feinberg, C.D.P." <[EMAIL PROTECTED]>
Cc: <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]>
Sent: Wednesday, May 29, 2002 6:53 AM
Subject: Re: New HIPAA Regulations Being Published
David,
What would be the next steps following the NPRM for the addenda? Will
they be final by the Oct 2003 drop dead date?
Thanks,
Tami Leaver
Sr. Application Analyst
Medstar Information Systems
410-933-6905
email: [EMAIL PROTECTED]
