Re: 275 attachment

[Zon Owen]

Kathy,   If it showed up in the regulations, it would probably be in the as yet unpublished Claim Attachments rule.  I didn't cite anything official because I am not aware of anything official that would compel this interpretation.   One area where this has come up is with vision claims.  A major vision payer reportedly asks for many technical details regarding lenses and/or eye measurements that are not part of the standard, and is reportedly intending to continue to require them under HIPAA.  Their authority for doing that could be their right to require claim attachments, and I believe that that was the occasion for one discussion where Stanley Nachimson of HHS is reported to have made such a statement.   But this hasn't been fully sorted out yet, and I'm not sure that I agree with the reasoning.  It would seem that the right to require attachments at all would imply the right for some sliver of the industry to require them consistently.  I.e., it may not be needed for all health care claims, but it might be needed for virtually all claims submitted by a given specialist due to the nature of that specialty.   We have a similar issue with the interpretation of the DDE rule, where a payer could conceivably ask for more information in that environment than is supported by the claim standard, but argue that that is OK because it constitutes a claim attachment transaction, rather than an addition to the claim transaction.  Minus the attachment rule, I don't know of anything in the rules that would prohibit this.  And, even with an attachment rule, and with an initial group of standardized attachments, it might still be several years before a specific type of attachment was standardized, and there might not be any particular limit on what could be requested until that particular type was standardized.   All of that said, on a practical level, I would prefer that payers went on a data diet by revising their benefit plans is such a way as to reduce their need for attachments and for much of the data currently included in the claim-related transactions.  Many have done just that to reduce their own administrative expenses.  But I would expect that the government plans would be the worst offenders when it comes to asking for all kinds of additional information, whether that be in the form of claims data, attachment data, certifications, authorizations, or whatever.   So, in sum, I think that it is reasonable to suggest that there might be a problem if a given payer were to request additional data with every claim, whether they called it an attachment or not.  But it may still be several years before there is any meaningful restriction of their right to do so, unless HHS itself comes up with something more specific than I have heard about.    - Zon Owen - (808)597-8493   PS:  Maybe Maria Ward or another claim attachment guru can add a helpful comment or two.   ----- Original Message -----   From: Carlin, Kathy (Contractor) To: WEDI SNIP Transactions Workgroup List Sent: Thursday, November 14, 2002 11:05 AM Subject: RE: 275 attachment Zon, your comments are very encouraging.  If payers can require attachments for any data they want, then the standards lose their effectiveness, and providers are back in the business of supporting separate requirements by payer.  Is anything being done to build this into the regulations?   Thank you,   Kathy Carlin, Principal Consultant Siemens Medical Solutions   UCLA Phone 310-301-5219 UCLA email:  [EMAIL PROTECTED] Siemens Voicemail 610-219-2067 Siemens email:  [EMAIL PROTECTED]   -----Original Message----- From: Zon Owen [mailto:[EMAIL PROTECTED]] Sent: Thursday, November 14, 2002 10:56 AM To: WEDI SNIP Transactions Workgroup List Subject: Re: 275 attachment   Suzanne,   I can't cite a regulation or an HHS FAQ on this, but Stanley Nachimson of HHS has stated on a number of occasions something to the effect that an attachment that is required with every claim is the equivalent of adding data to the claim standard, and would thus be problematic.  I.e., if it is needed all of the time, it should be part of the claim, not part of an attachment, and you can't unilaterally add data to the claim transaction.  So you might want to contact HHS directly on this.    - Zon Owen - (808)597-8493   ----- Original Message -----   From: Suzanne Azariah To: WEDI SNIP Transactions Workgroup List Sent: Tuesday, November 12, 2002 8:04 AM Subject: 275 attachment   Dear Group Members, We would like to know if we can require a 275 for every 837.  This would give us the ability to collect data such as DSMIV codes and more definitive ethnicity codes.  Is there a reason why this cannot be done?  Thanks. Suzanne   --- 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. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. 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