I agree with Maria that this will be less of a problem once there really is an attachment rule, compliance deadlines and defined standards for all attachments.  But we are a long way from that panacea today!  Until we reach that point, it is definitely probable that payers will be (and are) randomly developing their own attachment formats and requirements, as they always have.  And the fact that some payers would like to require such attachments to "get around" the defined standard format is a serious industry concern. 
 
I agree with Zon that CMS/HHS representatives have spoken very definitely, and often, on this subject.  The message has been that payers who wish to be compliant may not set up rules that require an attachment be provided for every claim.  Payers who need data with every claim must work with the standards organizations to have that data added to the standard format(s).
 
Cathy

 
----- Original Message -----
Sent: Thursday, November 14, 2002 9:49 PM
Subject: RE: 275 attachment


Those of you who know me know it was only a matter of time until I sent this:)

Lets not jump the gun on this.  The intent of the standardized 275 / HL7 attachment was never to prohibit a payer(s) with demonstrated need to be able to create and request certain attachments.  Requests for all new attachment types will go through the same process (DSMO, NCVHS) as do requests for any other kind of data content desired to be included in IG's adopted for use under HIPAA.  Bottom line...payers won't randomly develop their own attachment types - remember these are standards that are "adopted" under HIPAA, therefore they go through the same public review processes as all others.

As for the definition of an "attachment" I suspect this will be better worked through once the NPRM is out and the industry comments.  I know that there is NO hard fast rule for this definition as of today.  I will also say  that the intent of the developers of the attachment recommendation was never for it to be required by a payer for every single claim they receive from a provider.  This was never even discussed and it would not be supported by our committee.  If I had to speculate I'd say it's a safe bet that it was never the intent of CMS either.  

This isn't an "easy" topic - there are a lot of layers of issues once you start peeling the onion.  We hope that having created a standard way to transmit this information electronically will be viewed by the healthcare community as the very positive thing that it is.  Beyond that, we have to start working through the policies, business issues etc that will be relevant to such an electronic transmission.

The Attachment SIG in HL7 has been working on these kinds of things since 1997.  We invite any and all who feel they have something positive to contribute to the electronic claims attachment discussion and development to join us.  The more people that get involved and give their input now, the better off we'll all be.


Maria

Maria Ward
PricewaterhouseCoopers, LLP
Healthcare Consulting Practice

CoChair, HL7 ASIG
Chair, DSMO Steering Committee
Member, NUCC
312.298.2586








"Carlin, Kathy (Contractor)" <[EMAIL PROTECTED]>
11/14/2002 03:05 PM

Please respond to "WEDI SNIP Transactions Workgroup List"
       
        To:        "WEDI SNIP Transactions Workgroup List" <[EMAIL PROTECTED]>
        cc:        
        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 and more definitive ethnicity codes.  Is there a reason why this cannot be done?  

Thanks.
Suzanne

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