Some State Medicaid Programs Will Not Be Ready For Oct. 16 Deadline

September 15, 2003 – A few state Medicaid programs are now ready to accept electronic transactions, but many more are not yet and possibly will still not be ready by the October 16 Transactions and Code Sets (TCS) compliance deadline. Last month, Federal Computer Week reported Delaware is more than a year ahead on its HIPAA compliance and may be the first state to be "officially noted" as HIPAA compliant by CMS. Meanwhile, New Mexico Business Weekly reported that New Mexico's state government is in danger of missing the Oct. 16 deadline, though state officials say they will meet the deadline for submitting standardized electronic health care forms.

Read more about Delaware's HIPAA compliance.

Read more about New Mexico's HIPAA efforts.

Below is the TCS compliance status for 27 other states:

Alabama has postponed its implementation date from the original target date of September 27, 2003, saying it will notify all state providers at least three weeks in advance of the new implementation date. "You must continue to use current claim submission methods until the new implementation date. Claims or other transactions submitted in the new HIPAA compliant formats will not be accepted until the implementation of the HIPAA compliant system. In addition, the statewide HIPAA workshops will continue as scheduled. If you have any questions, please contact your EDS Provider Representatives or the EDS Provider Assistance Center at (800) 688-7989."

Read Alabama's Medicaid Alert (PDF).

Alaska's Department of Health and Social Services Division of Medical Assistance (DMA) is developing a new Medicaid Management Information System (MMIS) that will be HIPAA compliant. However, the new MMIS will not be available by the compliance deadline of October 16, 2003. DMA will not be able to accept claims in the electronic format required by HIPAA by the compliance date, but will continue to accept claims in the electronic format currently used by providers. DMA is not presently testing HIPAA compliant claims. They will notify providers promptly when they are able to test and accept HIPAA compliant electronic claims.

The State of Arizona, recognizing the risks associated with HIPAA Transactions and Code Sets development, has posted its Medicaid program's HIPAA Transactions and Codes Sets Contingency Plan, identifying the contingencies or alternatives that provide possible interim solutions to delays in implementation.

Read Arizona's Medicaid Program Contingency Plan (PDF).

Arkansas Medicaid's Provider Electronic Solutions software version 2.0, which produces HIPAA-compliant electronic transactions, was to be available for download from the Arkansas Medicaid web site the week of September 15. While claims cannot be submitted with version 2.0 until October 13, providers can keep their old version, load the new version, and begin preparing for the changeover by developing their PES lists. All testing for providers and vendors ends September 26.

Connecticut providers will be able to send HIPAA compliant transactions to EDS in targeted claim cycles after receiving approval from its EDI department. For a two-month period of time following the implementation date, the current format will continue to be supported with the exception of Long Term Care and Medical Transportation claims. DSS and EDS are implementing in a staggered schedule to reduce project costs and risks. All health payers must be compliant by October 2003.

Kentucky's Department for Medicaid Services amended its original plan to implement the new pharmacy NCPDP Version 5.1 point of sale (POS) systems. The date was rescheduled to Sunday, September 14th.

Read Kentucky's notification (document file).

New York Medicaid had said it would start accepting and processing HIPAA transactions on September 27, 2003. On September 10th, however, it sent a letter to its state Medicaid providers that its Medicaid Management Information System (MMIS) will not be able to accept and process certain HIPAA-compliant transactions by September 27th, specifically the professional claim (837P), the institutional claim (837I), the dental claim (837D) and the claims inquiry (276) transactions. They will be able to accept and process HIPAA compliant eligibility verification inquiry and response (270, 271), service authorization (278), and NCPDP (retail pharmacy) transactions through the eMedNY system by October 16, 2003.

Read NY Medicaid's September 10th letter (PDF).

North Carolina: Both the X12N standards, Version 4010A1 for electronic transactions, and the introduction of the new North Carolina Electronic Claims Submission web-based tool (NCECS-Web) for electronic claim submission scheduled for September 14, 2003 were delayed. Providers will be notified of the status of the implementation project in the October 2003 general Medicaid bulletin.

Maine's Bureau of Medical Services has been working with a contractor to deploy a new electronic claims management system, known as MECMS, which will be web-based and HIPAA compliant. This system will also provide increased functionality for providers with an Internet connection to enter and submit claims electronically. Based on the projected schedule, however, MECMS will not be implemented until February 2004. The Bureau sent a memo providing advance notice of this fact and also outlining its plan to address this issue for the intervening four-month period. In addition, the attachment to this memo provides the information needed to make changes to providers' system in order to submit claims electronically once MECMS is implemented.

Read Maine's provider memo outlining its interim plan (document file).

Mississippi's Medicaid Management Information System (MMIS) will implement all HIPAA mandated electronic health care transactions on October 1, 2003.

Missouri Medicaid has analyzed how providers must bill for services in order to be in compliance with the implementation of national transaction and code sets. HIPAA mandates the use of standard Health Care Procedure Coding System (HCPCS) code sets; however, it does not require states to add coverage for services that it does not currently cover. With the implementation of HIPAA national standards by Missouri Medicaid, non-HIPAA compliant methods of electronic claims submission will be phased out and will no longer be available for use by providers. The existing formats and media will be available during a short grace period for providers unable to produce a HIPAA-compliant 837 professional transaction starting October 16, 2003. Providers may continue to bill current Missouri Medicaid formats and media during this grace period.

Providers serving clients of the Montana Department of Public Health and Human Services (DPHHS) need to know whether DPHHS will be able to accept X12N formats after Oct. 16 and whether DPHHS will continue to accept current formats for a limited time after Oct. 16. The answer to both questions is yes. There are seven different ways providers will be able to submit claims to DPHHS and its claims processing contractor, ACS State Healthcare.

Nebraska's Health & Human Services System presented a HIPAA Update at its September 9 Policy Cabinet meeting, followed by a presentation on a "Business Contingency Plan" at its September 9 meeting (the minutes for either meeting are not yet available).

First Health Services Corporation, Nevada (FHSC NV) Medicaid's web site has a 'Go Live' date of October 1, 2003.

North Dakota Medicaid's Update of 9/12/03 on HIPAA Transactions says North Dakota will NOT be accepting any 4010 claims in production. In September 2003, the Department was to be testing 4010A transactions (835 and 837 only) with providers and in mid-September 2003, the Department was scheduled to accept 4010A transactions in production.

The Ohio Department of Job and Family Services (ODJFS) requested an extension to implement the Transactions and Code Sets rule from the federal Centers for Medicare and Medicaid (CMS) in order to be fully HIPAA compliant on October 16, 2003.

Oklahoma could save more than 20 million through 2007 with its new computerized claims-processing and payment system for Medicaid clients, according to the Daily Oklahoman (September 12, 2003). A recent report to the Oklahoma Health Care Authority, the state's Medicaid agency, indicated the Internet system is paying claims faster and more accurately. The new claims-processing and billing system has been so successful it has received certification from the Centers for Medicare and Medicaid Services, which predicted the 20 million savings through 2007, after being reviewed by federal government inspectors in June. Approval of the payment system means the federal government will pay 75 percent of the operational costs of the system rather than the customary 50 percent, officials said. The new system incorporates the format required by HIPAA, which must be in place by Oct. 16.

Oregon's transition is slated to be complete Sept. 30.

The Pennsylvania Department of Public Welfare (DPW) is ready to accept the 837, 835, NCPDP 5.1, and 270/271 transactions for those providers that want to submit their claims in these formats.

DPW’s long-term and permanent solution to the HIPAA requirements began in June 2001 when it released a Request for Proposal to procure a new HIPAA ready Medicaid Management Information System (MMIS). Based on current implementation schedules, our new MMIS should go live in the spring of 2004.

The gap between 2002 and the spring of 2004 required them to develop a short-term plan that involves the use of the current MMIS to comply with the HIPAA requirements to the best of its ability. This plan utilizes EDS as a clearinghouse to accept provider’s HIPAA compliant transactions and then convert them back to the formats recognized by the current MMIS. This process will also work in the reverse when information is returned to the provider.

The Office of Medical Assistance Programs (OMAP) is alarmed by the low number of MA providers that are certified to exchange HIPAA transactions.

Tennessee: To date, no clearinghouse has successfully completed EDI testing with the Tennessee Department of Health.

All HIPAA transactions will be implemented by Utah Medicaid prior to October 16, 2003. Local codes (Y codes) have been cross-walked to national standard codes with implementation dates ranging from July 2003 through October 2003.

Read Utah's Provider Letter (PDF).

View the HIPAA and Medicaid in Utah page.

In February 2002, the State of Vermont issued its "Transactions and Code Sets Implementation Advance Planning Document (IAPD)" which included a Contingency Plan for Transactions and Code Sets Noncompliance:

Vermont considered two possible non-compliance scenarios and the respective counter plan for each:

1. The translator arrangement is not ready.
   Plan A: Vermont retains the ability to process pre-HIPAA non-standard transactions and code sets.
   Plan B: EDS will create a temporary solution by creating a critical path between the translator and the MMIS with the data elements necessary to process HIPAA compliant claims.
   
2. Providers are not ready.
   Plan A: Since the translator will be in place, the MMIS will be able to process pre-HIPAA transactions.
   In either scenario, Vermont will ensure that beneficiaries receive services and that providers receive payment.
   The IV and V (i.e., independent verification and validation of the modified system against specifications) will identify areas of risk for non-compliance. Accordingly, Vermont will proceed with correcting non-compliance issues.

If unforeseen circumstances render Vermont in non-compliance of HIPAA, a memo will be issued to the AHS Secretary and Governor with the circumstances surrounding the noncompliance and recommendations for courses of action. It also may be appropriate to notify and work with the Senate and House Health and Welfare Committees. In addition, a press release will be issued to providers and the public. The press release will provide background, current processing information and a forecast of Vermont’s revised expected compliance date."

Virginia Medicaid implemented a new MMIS on June 20, 2003. Effective with that implementation, it began accepting and producing transactions in the ASC X12N format.

On Labor Day, the Washington State Medicaid program and its primary HIPAA vendor, Affiliated Computer Services (ACS), successfully installed an upgraded version of its Medicaid Management Information System (MMIS) – the key state computer system used to process some $50 million in health-care providers’ reimbursements each week. The upgrade brings the MMIS into compliance with HIPAA.

Washington State is modifying its current Medicaid Management Information System (MMIS) computers to handle the new HIPAA-compliant claims. But Medicaid is not turning off its current claims-handling process, so Washington providers will have a backup if their HIPAA claims run into difficulty. MAA also advises against reverting to paper claims, because the processing takes longer and will delay the entire claims-reimbursement system.

As a contingency plan, the Medical Assistance Administration (MAA) is instructing pharmacists to retain their 3.2 system capability. Medicaid is planning dual support for all providers, and pharmacy claims filed on the old system will still be accepted on October 16 as a backup.

MAA will provide dual support during the transition period, which means current electronic claims systems can serve as backup plans. MAA’s top priority will be to continue health-care coverage for clients and timely reimbursement for providers.

View the West Virginia Department of Health & Human Resources (WVDHHR) Bureau For Medical Services'
Billing and Electronic Claims Submission Chart.

The Wisconsin Division of Health Care Financing (DHCF) requires billing providers (including users of the free claims submission software, also known as Provider Electronic Solutions) to sign and return a Trading Partner Agreement to the DHCF EDI Department by September 1, 2003.

View Wisconsin's Testing Schedule.

Wyoming's Medicaid program goes live with HIPAA standard transactions on September 29.

HIPAA testing readiness of the Medicare Contractors as of August 29, 2003 (PDF).