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Standards for Electronic Healthcare
Claims Attachments
C. Guiding Principles for Standard
Selection
1. Overview
The implementation teams charged
with designating standards under the
statute have defined, with significant
input from the health care industry, a
set of common criteria for evaluating
potential standards. These criteria were
based on direct specifications in the
HIPAA, the purpose of the law, those
principles that support the regulatory
philosophy set forth in Executive Order
12866 of September 30, 1993, and the
PRA of 1995. In order to be designated
as a standard, a proposed standard
should do the following:
- Improve the efficiency and
effectiveness of the health care system
by leading to cost reductions for, or
improvements in, benefits from
electronic HIPAA health care
transactions. This principle supports the
regulatory goals of cost-effectiveness
and avoidance of burden.
- Meet the needs of the health data
standards user community, particularly
covered health care providers, health
plans, and health care clearinghouses.
This principle supports the regulatory
goal of cost-effectiveness.
- Be consistent and uniform with the
other HIPAA standards (that is, their
data element definitions and codes and
their privacy and security requirements)
and, secondarily, with other private and
public sector health data standards. This
principle supports the regulatory goals
of consistency and avoidance of
incompatibility, and it establishes a
performance objective for the standard.
- Have low additional development
and implementation costs relative to the
benefits of using the standard. This
principle supports the regulatory goals
of cost-effectiveness and avoidance of
burden.
- Be supported by an ANSI-Accredited
Standards Developing
Organization or other private or public
organization that would ensure
continuity and efficient updating of the
standard over time. This principle
supports the regulatory goal of
predictability.
- Have timely development, testing,
implementation, and updating
procedures to achieve administrative
simplification benefits faster. This
principle establishes a performance
objective for the standard.
- Be technologically independent of
the computer platforms and
transmission protocols used in HIPAA
health transactions, except when they
are explicitly part of the standard. This
principle establishes a performance
objective for the standard and supports
the regulatory goal of flexibility.
- Be precise and unambiguous but as
simple as possible. This principle
supports the regulatory goals of
predictability and simplicity.
- Keep data collection and paperwork
burdens on users as low as is feasible.
This principle supports the regulatory
goals of cost-effectiveness and
avoidance of duplication and burden.
- Incorporate flexibility to adapt more
easily to changes in the health care
infrastructure (such as new services,
organizations, and provider types) and
information technology. This principle
supports the regulatory goals of
flexibility and encouragement of
innovation.
We believe that the standards being
proposed in this regulation meet the
requirements of these guidelines.
2. General
Converting to any standard would
result in one-time conversion costs for
covered health care providers, health
care clearinghouses, and health plans.
Some covered health care providers and
health plans would incur those costs
directly and others may incur them in
the form of a fee from health care
clearinghouses or, for covered health
care providers, other agents such as
practice management and software
system vendors. We do not include
estimated costs to health care
clearinghouses in our analysis, since
these costs are incurred on behalf of
covered health care providers and
health plans, and are ultimately borne
by them. Including health care
clearinghouse costs in this analysis
would therefore count those costs twice.
We also do not include estimated
costs for health plans in this analysis,
because no relevant data were available.
The lack of data overall is discussed in
the section called "limitations."
The standards named in this proposed
rule compare favorably with typical
ASC X12 and HL7 standards and code
sets in terms of simplicity, ease of use
and cost. Covered entities have a variety
of ways in which they can choose to
send and/or receive an ASC X12
transaction or HL7 message, including
internal reprogramming of their own
systems, contracting with vendors and
purchasing off-the-shelf translator, or
interface engine programs.
The selection of the LOINC code set
for conveying meaningful information
between trading partners represents
another opportunity to control user
costs, since this code set is available for
use without payment of licensing fees.
List of Subjects in 45 CFR Part 162
Administrative practice and
procedure, Electronic transactions,
Health facilities, Health insurance,
Hospitals, Incorporation by reference,
Medicare, Medicaid, Reporting and
recordkeeping requirements.
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