I think the filing of the extension is to indicate that CMS will be ready by October 2003. To throw in another wrinkle - I understand that CMS allows direct data entry of claims and expects to continue to offer an 837 version of this service - DDE is required to be compliant in content, but not format, with the 837 transaction. Since DDE doesn't involve the exchange of EDI transactions, nor does the entity submitting a claim via DDE need to be set up as a trading partner, they aren't in fact submitting HIPAA EDI transactions. Therefore, if a provider only uses DDE or paper for claims submission is the provider that only submits claims via DDE or paper in fact excluded from the definition a covered entity?
Becky Reed Principal for Alera Solutions -----Original Message----- From: David Frenkel [mailto:gefeg@;att.net] Sent: Thursday, October 10, 2002 1:59 PM To: [EMAIL PROTECTED] Subject: RE: FW: Small provider You are assuming CMS will be ready to receive HIPAA compliant transactions by Oct 2003. CMS has filed for the extension. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 425-260-5030 -----Original Message----- From: Jensen, Christine [mailto:Christine.Jensen@;dhha.org] Sent: Thursday, October 10, 2002 11:44 AM To: [EMAIL PROTECTED] Subject: RE: FW: Small provider The answer is yes, a covered entity must conduct EDI transactions using the HIPAA TCS rule defined standards, regardless of the CE's size. Christine Jensen HIPAA Project Manager Denver Health 303.436.7942 -----Original Message----- From: Sherri Gerhardt [mailto:Sherri.Gerhardt@;PREMERA.com] Sent: Thursday, October 10, 2002 12:35 PM To: '[EMAIL PROTECTED]' Subject: RE: FW: Small provider Another angle of this response that I would like a reply to is that if a small provider does choose to submit claims to Medicare electronically, must they do so using a HIPAA compliant transaction? My thought is Yes, but I have heard differing opinions. Thank you! -----Original Message----- From: Herb Larsen [mailto:herb.larsen@;quovadx.com] Sent: Thursday, October 10, 2002 11:13 AM To: '[EMAIL PROTECTED]' Subject: RE: FW: Small provider Patricia, thanks for the clarification. Can you take a look at Kathy Carlin's last question, regarding Medicare secondary claims, and provide some insight into that scenario, as well? I would appreciate it! Thanks- -----Original Message----- From: Patricia Peyton [mailto:PPeyton@;cms.hhs.gov] Sent: Thursday, October 10, 2002 2:02 PM To: [EMAIL PROTECTED] Subject: Re: FW: Small provider I work in HHS and would like to respond to this issue. Here is the question: If a small provider (one physician) has the methodology to send claims electronically, do they have to send them electronically to Medicare? Right now, they send them via paper. Here is the response: They may continue to send paper. The Administrative Simplification Compliance Act (ASCA) prohibits Medicare from paying paper claims received after October 16, 2003, except in certain situations. Those situations waive the requirement to submit electronic claims to Medicare after October 16, 2003. Those situations are: the provider is a small provider; the provider has no means to send claims electronically; other situations that the Secretary may deem appropriate. ASCA defines a small provider as a provider of services with fewer than 25 full-time equivalent employees, or a physician, practitioner, facility or supplier (other than a provider of services) with fewer than 10 full-time equivalent employees. There is no gross revenue figure attached to the definition of a small provider in this legislation. Because the provider in question is small by the ASCA definition, it is waived from the requirement to submit Medicare claims electronically. If it has the means to submit electronic claims to Medicare, it certainly may do so but that is not a requirement of this law. A regulation will be published that will clarify this ASCA provision. At this time, any information needed by Medicare providers with respect to this provision will be furnished to them by their Medicare carriers or fiscal intermediaries. These providers need take no action with regard to this provision until they receive that information. Patricia Peyton HIPAA Project Staff Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244-1850 (410) 786-1812 >>> [EMAIL PROTECTED] 10/10/02 01:36PM >>> I asked this very similar question. Below is the response I received. Linda -----Original Message----- From: AskHIPAA AskHIPAA [mailto:AskHIPAA@;cms.hhs.gov] Sent: Thursday, October 03, 2002 5:42 PM To: [EMAIL PROTECTED] Subject: Re: Small provider ASCA contains a provision which requires the electronic submission of Medicare claims as of October 16, 2003. However, ASCA provides for exceptions to this requirement if the entity is considered "small". ASCA defines "small" as a provider of services who does not file electronic claims, with fewer than 10 full time employees and who earns less than 5 million in gross revenue. The Secretary in unusual cases and in situation may also grant waivers where there is no method available for the submission of claims in an electronic form. There is nothing for you to do now. HHS will be issuing guidance which will provide further clarification on these provisions and will explain the waiver applications process. >>> "Shemely, Linda" <[EMAIL PROTECTED]> 10/02/02 11:26AM >>> If a small provider (one physician) has the methodology to send claims electronically, do they have to send them electronically to Medicare? Right now, they send them via paper. ********************************************************************** To be removed from this list, send a message to: [EMAIL PROTECTED] Please note that it may take up to 72 hours to process your request. ====================================================== The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. 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