In light of the Centers for Medicare and Medicaid Services’ (CMS) contingency plan to accept non-compliant electronic HIPAA transactions after the October 16 deadline, the Healthcare Information Management Systems Society (HIMSS) has offered some recommendations for covered entities:
- Don’t drop your current contingency plan and do not assume there will be a lengthy reprieve.
- Continue testing and obtain firm testing dates from all trading partners.
- Review and follow the contingency plan for claim submissions for Medicare and Medicaid if a covered entity has not successfully tested with CMS to date.
- Contact other payers besides CMS to determine their readiness and whether they will accept non-compliant transactions.
- Ask for a copy of your trading partners’ contingency plan.
- Document everything you have done to become compliant, and especially your determination of what contingency planning needs to be done.
- Consider contracting with a third-party vendor that specializes in testing and certification for HIPAA compliance to assist with determining if your transactions or those of your trading partners are compliant.
- Keep a close watch for future CMS announcements regarding how long the contingency plan will remain in effect, at www.cms.gov/hipaa/hipaa2.
September 25, 2003
Related Reading
CMS to accept non-compliant transactions after October 16, September 23, 2003
New HIPAA transaction standards in spotlight, September 16, 2003
U.S. health officials warn of potential payment "train wreck", September 12, 2003
X-ray film recycling raises HIPAA concerns, July 10, 2003
Separating HIPAA facts from fiction, May 12, 2003
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