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Standards for Electronic Healthcare
Claims Attachments

E. Electronic Health Care Claims Attachment Content and Structure

[If you choose to comment on issues in this section, please include the caption "ATTACHMENT CONTENT AND STRUCTURE" at the beginning of your comments.]

As noted, there are two separate transactions associated with the electronic claims attachment. One transaction is a health plan's request for health care claims attachment information, and the other is the health care provider’s response, which includes submission of the attachment information.

Each of these transactions contains administrative information that identifies the individual, date of service, and other information that permits the health care provider to identify the appropriate individual and claim, and enables the health plan to associate the electronic attachment material with the proper claim. In addition, the attachment request must have an unambiguous way to specify the clinical or other information needed, and the attachment response must have an unambiguous way to label the information being provided and to convey responses in a consistent, predictable manner.

Example: ABC Ambulance Company submits a claim for transporting M. Smith on a certain date. The health plan cannot adjudicate the claim without knowing M. Smith's weight. The health plan sends a request for the individual's weight to ABC Ambulance Company and includes the individual's name, date of service, type of service, the control number it is using to identify the claim, and other information that will allow ABC to locate the individual's record. This information, when returned along with the response, will also enable the health plan to associate this new piece of data with the correct claim. The ABC Company sends the requested information back to the health plan, it is associated with M. Smith's claim, and the claim continues through the adjudication process.

In this example, the health plan wants the individual's weight as reported by the individual (rather than an estimate made by the attendants) expressed in pounds, not kilograms. The request will contain a code that reflects this exact request, and the response will return the code with the individual's weight, expressed in pounds.

Thus, the standards we are proposing for any of the named electronic attachments types will specify:

  • The administrative information contained in the request and response;
  • The attachment information (also referred to as the additional information specification) contained in the response;
  • A code set for specifically describing the attachment information;
  • A code set modifier for adding specificity to the request; and
  • The format that will contain all of this information.

The size of the file in the response transaction will be impacted by the option the health care provider chooses for the submission—either text and imaged documents or coded data. With imaged documents, the size of the file within a single response transaction could become large. The implementation guide for the X12 275 response transaction permits up to 64 megabytes of data in a single transaction. Industry comment on file size is also welcome.

In sum, the proposed standards are those that have been under development for over eight (8) years by the HL7 ASIG. Meanwhile, the health care industry itself has undergone significant change. It is, therefore, critical that appropriate industry representation reviews and then weighs in on these standards: The attachment content, and format, and the transaction’s function. As discussed throughout this preamble, we are soliciting comments from all affected covered entity types (covered health care providers, health plans, health care clearinghouses and Medicare prescription drug discount card sponsors) and their business associates (practice management vendors, software vendors, document storage contractors and others) about these proposed standards. In this paragraph, we reference Medicare prescription drug discount card sponsors as a covered entity. These organizations are considered covered entities until 2006, when the new Medicare prescription drug program becomes effective. Based on the timing of the electronic health care claims attachments final rule, the requirements of that final rule may or may not be relevant to such organizations.

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