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Under
consideration is a signed electronic certification document (BBA requirement) appended
externally to the ISA-IEA communications envelope of a data file. Would this be a violation of X12
transmission standards? For
details, please see information below.
If you have questions concerning contents
of this email, please contact me.
Thank you in advance for your assistance. BACKGROUND Current
Data Submission Forms Attesting to Accuracy, Completeness, and Timeliness Currently, with regards to
encounter data Arizona requires encounter data certification forms to be on
file prospectively prior to encounter submissions. �
An Encounter
Submission Notification form signed by the CEO or Administrator, which states
that MCO agrees to submit all encounter data, and correct any encounter
submission errors within the limited time frame prescribed by AHCCCS
Administration; and �
An Electronic
Data Interchange Agreement form signed by the CEO or Administrator, which
states that MCO “certifies that the encounter data so recorded and submitted as
input data are in accordance with all procedures, rules, regulations and
statutes now in effect. If any of
those procedures, rules, regulations or statutes are hereafter amended,
contractor agrees to conform to those amendments of which contractor has been
notified.” These forms are held on file by
the AHCCCS Encounter Unit for all current and subsequent MCO encounter
submissions and revised, as needed. Current Encounter Processing Environment Encounters are submitted
to an FTP server at MCO convenience, e.g., 2-3 times per week, weekly,
bi-weekly, or monthly. The FTP
server generally receives encounter data about 24 out of 30 days a month. This data is processed daily, i.e.,
syntax check on data to verify that numeric fields have numeric values and
alpha fields have alpha values and, if syntax is clean, the file is sent
through edit processing. Encounter
outcomes from this processing are either finalized (data passed all encounter
edits and is “clean”) or pended (data failed at least one encounter edit). MCOs must correct pended encounter
data. Balanced
Budget Act (BBA) Certification Attesting to Accuracy, Completeness and
Truthfulness
The BBA certification requirements (Federal Register, Vol 67,
No 115, Friday, June 14, 2002, Page 41112), under Subpart H requires: �
�438.602 that “as
a condition for receiving payment under Medicaid managed care program an MCO
must comply with the applicable certification ….of this subpart.” �
�438.604 that
certified data must include, but not limited to, “enrollment information,
encounter data, and other information required by the State and contained in
contracts, proposals, and related documents.” �
�438.606 certification
by source, content, and timing. o
For source, data
must be certified by MCO’s CEO, CFO, or designated individual. o
For content,
“certification must attest, based on best knowledge, information, and belief,
as follows: �
To the accuracy,
completeness and truthfulness of the data; and �
To the accuracy,
completeness and truthfulness of the documents specified by the State.” o
For timing, MCO
“must submit the certification concurrently with the certified data.” ISSUE
Arizona will modify its current
forms to include BBA requirements.
In order to satisfy the concurrent certification with file submission, personally,
I would rather develop an electronic certification document to be electronically
signed and appended (externally to ISA-IEA communications envelope) to each
MCO’s encounter data file transmitted to the FTP server. The document would be removed from the
outer envelope and stored electronically.
(Of course this assumes MCO’s CEO, CFO or designated individual has the
technology to electronically sign the document appended to the envelope.) Otherwise these documents will probably
be faxed to Arizona prior to or at the time of file transmission. And if documents are faxed, a manual audit
trail to match all files with documents will need to be developed and a
protocol to manually stop encounter processing until paper fax forms can be
matched to data file will be needed. [Commentary] If patients can have
a signature on file for claim submission and payer reimbursement to provider,
it seems odd that MCOs can not have a signature on file for data accuracy,
completeness, and truthfulness. Would an appended electronic
certification document externally to ISA-IEA communications envelope violate
X12N transmission standards? If
yes, manual protocols to compare certification documents with submitted data
files must be implemented. Brent Ratterree AHCCCS (Arizona Medicaid) Office of Managed Care 602.417.4571 v 602.417.4725 f [EMAIL PROTECTED] 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. You are currently subscribed to wedi-transactions as: [email protected] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org |
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