The loophole may be explained by the fact the initial publication in the Federal Register omitted the "on and after October 16, 2003" for health care claims.  This was corrected a week or so later.
----- Original Message -----
Sent: Monday, September 15, 2003 3:15 PM
Subject: RE: 4010 vs. 4010A for HIPAA Compliance

4010 without the addenda is compliant for those who did not file an extension "for the period from October 16, 2002 through October 15, 2003" (quoting the " Modifications to Electronic Data Transaction Standards and Code Sets" final rule).  

However, this rule also makes it clear that the only compliant version after October 16, 2003 is 4010 A1.

As an example, here are the references for the Professional Claim:

§162.1102 Standards for health care claims or equivalent encounter information transaction.

...

(b) For the period on and after October 16, 2003:

...

(3) Professional health care claims. The ASC X12N 837 − Health Care Claim: Professional, Volumes 1 and 2, Version 4010, May 2000, Washington Publishing Company, 004010X098 and Addenda to Health Care Claim: Professional, Volumes 1 and 2, Version 4010, October 2002, Washington Publishing Company, 004010X098A1. (Incorporated by reference in §162.920).


I don't see a loophole, since it says "AND Addenda....".

Larry Watkins
Executive Vice President
Claredi
Office: 801-444-0339 x204
Fax: 770-419-5295
Mobile: 678-463-0885
Email: [EMAIL PROTECTED]
 

-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]
Sent: Monday, September 15, 2003 5:00 PM
To: WEDI SNIP Testing Subworkgroup List
Cc: WEDI SNIP Testing Subworkgroup List
Subject: Re: 4010 vs. 4010A for HIPAA Compliance


I wonder what is being interpreted as a "loop hole"?  Anthem's
interpretation is that only version 4010 A1 is compliant as of 10/16/2003.

Cathy M. Ewbank
HIPAA Program Manager
(317) 488-6172


                                                                                                          
                      "Karyn White"                                                                       
                      <[EMAIL PROTECTED]>        To:       "WEDI SNIP Testing Subworkgroup List"            
                                                <[EMAIL PROTECTED]>                             
                      09/15/2003 03:43         cc:                                                        
                      PM                       Subject:  Re: 4010 vs. 4010A for HIPAA Compliance          
                      Please respond to                                                                   
                      "Karyn White"                                                                       
                                                                                                          
                                                                                                          




Our clearinghouse house said there is a "Loop Hole" in the final rule
regulation and some of the payers are considering themselves compliant with
the 4010.  Too bad for providers, who thought this was a standard
transaction.

>>> "Connie Hein" <[EMAIL PROTECTED]> 09/15/03 01:53PM >>>
We have been working with a client who contracts with one of the major
clearinghouses to conduct transactions.  This clearinghouse has stated that
they will not be able to accept 4010A transactions as of October 16, 2003.
Rather they will only accept 4010 version.



Is the payer compliant if they only accept version 4010 after the
compliance deadline?  It is our understanding that 4010A is necessary for
compliance, but they are telling us differently.



Thanks in advance for your response.



Connie Hein
Senior Consultant

Paramore Consulting, Inc.



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