Thankyou for clarifying my earlier statement Penny. My apology to the list
serve. With an accounting/auditing background and focus on COB I should
realize that others outside of that arena may have a different meaning of
what "supporting documentation" means to an accountant/auditor. In the
world of accounting/auditing supporting documentation means corroborative
information to support information already supplied such as an invoice from
an independent source to corroborate an expense charge on the books
already.
Again my apologies for any misunderstanding.
Robert C. Pozniak
NYS Department of Health
HIPAA Practice Group
One CSC Way
(518) 257-4511 fax (518) 257-4510
[EMAIL PROTECTED]
"Sanchez, Penny
L" To: [EMAIL PROTECTED]
<penny.sanchez@ed cc:
s.com> Subject: RE: Secondary Paper Claims
and EOB
09/17/2002 04:41
PM
Please respond to
transactions
Kris,
I agree with your interpretation; otherwise, why would the HIPAA law
require that the secretary adopt a standard for claims attachments.� I do
believe we can pend a claim to wait for supporting documentation that is
not otherwise contained in the 837; however, I do interpret the regulation
to mean that we can't pend a claim awaiting paper/hard copy validation of
data that is already contained in the�837 such as other health plan
payment amounts, etc.
Penny�Sanchez
-----Original Message-----
From: Owens, Kris [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, September 17, 2002 12:51 PM
To: '[EMAIL PROTECTED]'
Subject: RE: Secondary Paper Claims and EOB
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
 ! ;&! nbsp;
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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