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Policy and Legislative Positions
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July 16, 2001
To Whom It May Concern:
The undersigned organizations support administrative simplification for health care information and data. However, while regulations on Standards for Electronic Transactions were recently promulgated, standards for Security and Identifiers, equally important components of comprehensive administrative simplification, are not yet available. It is neither cost-effective nor efficient to put these regulations into practice on a piecemeal basis. Therefore, we have encouraged the Congress to support legislation, S. 836 and H.R. 1975, to extend the implementation period until two years after all initial administrative simplification standards have been issued and national identifiers for providers and health plans are available. These bills do not affect the implementation of the privacy regulations that went into effect in April 2001.
The Standards for Electronic Transactions (transactions and code sets) are one aspect of the Administrative Simplification provisions contained in the Health Insurance Portability and Accountability Act of 1996 (P.L. 104-191). The regulations on transactions and code sets require entities, such as health plans, providers, and health care clearinghouses, who transmit administrative data in electronic form (i.e. claims, enrollment, premium payments, eligibility) to use standard formats and code sets adopted by HHS.
The law provides for a two-year implementation period ending in October 2002, at which time entities conducting health care transactions through electronic media must be compliant. An extension is critical because:
- The staggered release, and implementation, of HIPAA administrative simplification regulations will require multiple systems upgrades and undermines efficient planning and budgeting.
- Compliance costs of implementing the transactions and code sets regulations are much higher than anticipated. Allowing a longer phase-in would facilitate spreading the costs over several years and permit better provider education and awareness.
- The current schedule does not provide adequate time for vendors to provide HIPAA compliant software and for trading partners to thoroughly test the new transactions.
- The elimination of local procedure codes requires significant time and resources to successfully move towards national standard codes without disruption. For example, local procedure codes are used extensively for new technologies and Medicaid has relied heavily on local codes to support their unique business needs, namely coverage of non-traditional services.
- Important implementation issues remain unresolved that could impede a successful move to standardization.
We encourage you to support an extension of the date upon which entities must be compliant with the administrative simplification standards until two years after all initial rules have been promulgated, and the national provider and health plan identifiers are ready and available.
Sincerely,
Advanced Medical Technology Association
American Academy of Facial Plastic and Reconstructive Surgery
American Academy of Neurology
American Academy of Ophthalmology
American Academy of Otolaryngology - Head and Neck Surgery
American Academy of Pediatrics
American Association of Health Plans
American Association of Clinical Endocrinologists
American Association of Neurological Surgeons
American Association of Orthopaedic Surgeons
American Chiropractic Association
American College of Family Physicians
American College of Osteopathic Emergency Physicians
American College of Osteopathic Family Physicians
American College of Osteopathic Surgeons
American College of Physicians-American Society of Internal Medicine (ACP-ASIM)
American College of Radiology
American College of Surgeons
American Health Care Association
American Managed Behavioral Healthcare Association
American Medical Association
American Medical Group Association
American Network of Community Options and Resources
American Optometric Association
American Osteopathic Association
American Psychiatric Association
American Public Human Services Association (Medicaid Directors)
American Society for Gastrointestinal Endoscopy
American Society of Anesthesiologists
Association for Health Center Affiliated Health Plans
American Urological Association
Blue Cross Blue Shield Association
College of American Pathologists
Congress of Neurological Surgeons
Delta Dental Plans Association
Health Insurance Association of America
National Association of Healthcare Access Management
National Association for Home Care
National Governors Association
Society of Cardiovascular and Interventional Radiology
Society of Critical Care Medicine
Society of Gynecologic Oncologists
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