The HIPAA Electronic Transaction Final Rule sets forth the requirement for
effective dates for codes set thusly:

Subpart J-Code Sets
? 162.1000 General requirements.

When conducting a transaction covered by this part, a covered entity must
meet the following requirements:

(a) Medical data code sets. Use the applicable medical data code sets
described in ? 162.1002 as specified in
the implementation specification adopted under this part that are valid at
the time the health care is furnished.

(b) Nonmedical data code sets. Use the nonmedical data code sets as
described in the implementation
specifications adopted under this part that are valid at the time the
transaction is initiated.

The other issues you raise re change management and version control will of
course have to be addressed at the time new versions of the HIPAA
specifications are adopted. Change management and version control are not
complicated but must be addressed in rules/requirements, etc. when moving
from one version to a newer one. Outside of HIPAA, most industries recognize
the business need to support multiple versions of any given EDI transction
set. Therefore, good commercial EDI management systems have this capability
(handling multiple versions of a transaction set/map by trading partner)
designed into them. It's truly not a big technical detail, just something
that must be managed. Change management/version control is not unique to EDI
and transcends most software systems/tools.

Rachel Foerster
Principal
Rachel Foerster & Associates, Ltd.
39432 North Avenue
Beach Park, IL 60099
Voice: 847-872-8070
Fax: 847-872-6860
eMail: [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]>
http://www.rfa-edi.com


-----Original Message-----
From: Christopher J. Feahr, OD [mailto:[EMAIL PROTECTED]]
Sent: Saturday, October 12, 2002 6:24 PM
To: Ratayski, Dawn; 'Ossont, Dawn x405'; '[EMAIL PROTECTED]'
Cc: [EMAIL PROTECTED]
Subject: RE: Code set effective dates


Dawn,
Please pardon the cross-post to "transactions", but this reminds me of a
couple other version-date issues that I'd like to bounce off the
transaction gurus.  If the code-set version is determined by "date of
service", what will drive the choice of code-set for transactions sent in
advance of the actual service... like the 270? In any case, it appears that
senders will have to maintain current and [possibly several] previous
code-sets so that claims submitted [up to a year, possibly] after a
code-set update can be created with the codes that were in effect on the
date of service... right?

My other question is regarding the correct transaction version to use,
which (if I understand correctly) is driven by the date of the transaction,
as opposed to the service-date.  So, does this mean that a claim
REsubmitted after the required implementation date of new transaction
version, would have to be reformatted for the new transaction version?

Would there ever be a scenario in which a sending system's translator or a
receiving system's validator would have to be able to support BOTH old and
new transaction versions?  If so, which date-field in the interchange
determines the choice of transaction version?

Thanks,
-Chris

Christopher J. Feahr, OD
Optiserv Consulting
[For the vision care industry]
Santa Rosa, CA
707-579-4984
707-529-2268 (cell/pager)
http://VisionDataStandard.org
http://Optiserv.com


At 03:09 PM 10/11/2002 -0400, Ratayski, Dawn wrote:
>Hi Dawn,
>
>I had the same concern and have brought it to the BCBSA association along
>with many other Blues plans nationwide to address with CMS. CMS is choosing
>not to change their practices at this time.
>
>HIPAA does not address this. CMS is a covered entity under HIPAA and the
>regs state the codes must be valid for the date of service for which they
>are billed. This means NO grace period.  CMS is sending and inconsistent
>message to the provider community by continuing to allow a grace period.
>
>[EMAIL PROTECTED]
>TCI Project Developer
>Blue Cross of Northeastern Pennsylvania
>
>
>
>-----Original Message-----
>From: Ossont, Dawn x405 [mailto:[EMAIL PROTECTED]]
>Sent: Friday, October 11, 2002 1:12 PM
>To: '[EMAIL PROTECTED]'
>Subject: Code set effective dates
>
>
>Hello,
>
>I'm looking for any information regarding the effective dates of ICD-9-CM
>and HCPCS code sets.  CMS currently allows providers to utilize a grace
>period.  For example, providers are not required to use HCPCS codes until
>4/1 (and they can start submitting 1/1).  How does HIPAA address this?
>
>Thanks!
>
>Dawn Ossont
>Reimbursement Team Leader
>Preferred Care
>
>phone:  716.327.2405
>fax:  716.327.2289
>e-mail:  [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]>
>
>
>
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