CMS: Put Transactions Testing on Schedule Now

Health Data Management reports the Centers for Medicare and Medicaid Services (CMS) is sending a letter to provider organizations imploring them to schedule HIPAA transactions testing with Medicare carriers and fiscal intermediaries. "Time is growing short," says Administrator Thomas Scully in the letter. "Please be sure to test and start sending and receiving HIPAA compliant transactions as early as possible to avoid any last minute problems." The letter contains a list of Web sites that provide information on the transactions and code sets (TCS) rule and how to schedule tests with Medicare contractors.

Karen Trudel, Deputy Director of the Office of HIPAA standards at the Centers for Medicare and Medicaid Services (CMS), addressed the issue of doing transactions testing now during CMS’ eighth HIPAA roundtable discussion held at the end of April:

"Some people have said that HIPAA will go away, or Congress will give us more time, or we don’t have to worry about this right now. Well, my response to that is first, HIPAA is the law. It could be said that Congress has already given us more time; time that is up on Oct. 16, and it began last Oct. 16, 2002, with the extension.

Deciding to ignore these requirements is a real gamble, and it’s one with high stakes because cash flow is the lifeblood of a healthcare provider and a healthcare claim is how that blood flows. If the flow of claims stops because of a non-compliance issue, then the cash flow stops too. The only way to assure this does not happen is to implement compliant transactions and then to test them with the health plan to make sure the claims can be submitted and processed and that accurate payments can be made.

We’re hearing that many plans and providers aren’t yet ready to test with training partners. In part that’s because covered entities and their vendors and business associates, some of them, waited until the regulation that modified the transaction standards were published. Well, here’s where we are now. The addenda have been published and the standards are set for compliance. So, it’s time to test now. Medicare’s ready to test the claim and remittance advice with providers using the new 4010A addenda version.

Call your carrier or a fiscal intermediary and make an appointment for testing as soon as you can. They also have information on their Web site showing their testing information and which submitters, like clearinghouses, have already tested successfully with them. If yours has done so you’re in good shape. The longer you wait the harder it will be to arrange testing. We expect a crowd of testers at the last minute and it may be difficult to accommodate them all. But don’t stop there. Call the other plans you submit claims to and talk to them about testing also. If your vendor hasn’t supplied you with a compliant version of their software yet, find out when they will and ask for help if you need it.

Professional associations have a wealth of information available for their members and CMS also has free outreach materials available. But the bottom line is, don’t underestimate the importance of the October 16th deadline. Don’t underestimate the work that’s involved in becoming compliant. And prepare and plan ahead to assure that your cash flow remains steady.

Meanwhile, the OIG recently issued a final report based on a survey of Medicare Part B providers. The survey, in asking if providers expect to comply with the HIPAA-mandated electronic data TCS standards, determined:

• 94% of the providers have a moderate to high level of satisfaction that they will be in compliance by October 2003
• 95% are using or plan to use external vendors to implement the standards
• 68% of the providers are purchasing new system components
• 27% have conducted any type of cost/benefit analysis for implementing the electronic standards
• 47% listed one or more barriers to compliance

The most common barriers listed:

• trading partners and vendors not being ready
• carriers and third-party payers not being compliant
• cost of implementation.

Read Health Data Management's article, "Medicare: Put Testing on Schedule."

Read the OIG's report, "HIPAA Readiness: Administrative Simplification for Medicare Part B Providers" (PDF).

View the Medicare Contractor HIPAA Testing Readiness Status Report as of July 11, 2003 (PDF).