Robert,

I'd be very interested in the e-mail from Stanley - it would be contrary to the way we currently do business.  How can we properly adjudicate a claim that requires supporting documentation - without that documentation?  That doesn't make sense to me unless we are wrapped around the term "adjudication".  We can take the claim into our system and put a "pend" on it waiting for documentation.  Would that be considered adjudication?

I went back to the regulations and in the comments page 50316 #4 Conducting the Transactions , Question #2, the response says:

"We interpret this provision to mean that there should be no degradation in the transmission of, receipt of, processing of, and response to a standard transaction solely because the transaction is a standard transaction....in the same time frame in which they processed transactions prior to implementation of HIPAA."

We currently receive claims that require supporting documentation which we take into our system and pend waiting for the documentation to show up.  I don't perceive from my reading of the regulations that this will have to change... this would be the same time frame as prior to HIPAA, and it is not due to the claim being in a standard format.

A bit further in the comments, page 50323 at the end of the response to the comments on Data Content, the response says:
 
"(A health plan may, however, request additional information through attachments.)" - So the regulations do acknowledge the continued use of attachments or supporting documentation.
 
As for the cite you give 162.925 (a) (2) "A health plan may not delay or reject a transaction, or attempt to adversely affect the other entity or the transaction, because the transaction is a standard."   I don't interpret this to say we can't wait for the supporting documentation, rather I interpret this as not delaying, rejecting or adversely affecting the claims because it is a standard, we are delaying it because it requires supporting documentation...  

I'm not yet convinced that we can't hold, i.e., pend a claim (COB or otherwise) to wait for the supporting paper documentation.  Please help me to understand where my interpretation is missing the point.

thanks,

Kris Owens
505/923-8108

"Complex systems evolve from simple rules"



-----Original Message-----
From: Robert C. Pozniak [
mailto:[EMAIL PROTECTED]]
Sent: Tuesday, September 17, 2002 10:40 AM
To: [EMAIL PROTECTED]
Subject: RE: Secondary Paper Claims and EOB



Kris, I will try and provide more info later but I have a conference call
to get on shortly.  The rule at 162.925 requires that a health plan may not
delay or reject a transaction, or attempt to adversely affect the other
entity or the transaction, because the transaction is a standard
transaction.  I also have an e-mail from Stanley Nachimson of CMS that
clearly states the adjudication cannot be delayed awaiting the supporting
documentation.  I believe there is more info in the preamble but just don't
have the time right now to search it out.

Robert C. Pozniak
NYS Department of Health
HIPAA Practice Group
One CSC Way
(518) 257-4511 fax (518) 257-4510
[EMAIL PROTECTED]


                                                                                                          
                      "Owens, Kris"                                                                       
                      <[EMAIL PROTECTED]>         To:       "'[EMAIL PROTECTED]'" <[EMAIL PROTECTED]>
                                               cc:                                                        
                      09/17/2002 12:22         Subject:  RE: Secondary Paper Claims and EOB               
                      PM                                                                                  
                      Please respond to                                                                   
                      transactions                                                                        
                                                                                                          
                                                                                                          






RE: Secondary Paper Claims and EOB

Robert,

I am curious about your final statement; " One thing to also note is that
when the
COB information is contained in the electronic 837 the payer may not hold
up adjudication awaiting for paper supporting documentation, i.e. paper
copies of remittance advices."

What in the regulations do you base that statement on?

thanks,

Kris Owens
505/923-8108

"Complex systems evolve from simple rules"

-----Original Message-----
From: Robert C. Pozniak [
mailto:[EMAIL PROTECTED]]
Sent: Tuesday, September 17, 2002 9:32 AM
To: [EMAIL PROTECTED]
Subject: Re: Secondary Paper Claims and EOB


I'd echo Kathy Simmons comments and add a couple.  Saying payers will be
ending support of paper claims and attachments may be true to the extent a
payer can attract providers willing to do nothing but electronic billing.
The electronic billing is not mandated by HIPAA with the exception of
certain size providers billing Medicare (read HR 3323).  Some providers and
their vendors may not have the ability to prepare an 837 COB
secondary/tertiary claim and therefore will be forced to file paper claims
(or the provider may need to change vendors to meet requirements of HR 3323
or other business process needs).  One thing to also note is that when the
COB information is contained in the electronic 837 the payer may not hold
up adjudication awaiting for paper supporting documentation, i.e. paper
copies of remittance advices.

Robert C. Pozniak
NYS Department of Health
HIPAA Practice Group
One CSC Way
(518) 257-4511 fax (518) 257-4510


                      "Dyke, David
#
                      IHTUL"                   To:
"'[EMAIL PROTECTED]'" <[EMAIL PROTECTED]>
                      <david.dyke@ndche        cc:
                      alth.com>                Subject:  Secondary Paper
Claims and EOB
                      09/17/2002 10:32
                      AM
                      Please respond to
                      transactions



Any feedback from the community on the following comment I keep hearing
regarding Secondary paper claims:

"HIPAA will kill paper secondary claims".

The logic being that with the mandated support for COB information in the
837 4010, payers and claim processors will be ending support of paper
secondary with attached EOB, and requiring electronic submission.

Thanks
David

David Dyke, NDCHealth

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