Implementation Guide Change Process (DSMO) THE HIPAA COLLOQUIUM at Harvard University Implementation Guide Change Process (DSMO) Tuesday, August 20, 2002 Gary Beatty Chair: X12N Insurance Subcommittee

HIPAA Implementation Guides Implementation Guides Cannot change more frequently than once per year X12 Standards change 3 times per year Any healthcare stakeholder can request changes including: Providers Payers Clearinghouses Healthcare Industry Representatives Federal / State Government HIPAA is adopting and mandating X12N Implementation Guides NOT X12 Standards! Anyone or organization can request changes to the HIPAA Implementation Guides.

HIPAA Implementation Guides National Committee on Vital and Health Statistics Public advisory body to the Secretary HHS Composed of 18 individuals from the private sector Public meetings and hearings National Committee on Vital and Health Statistics (NCVHS) Charged with advising the Secretary of HHS Composed of 18 PHD, MD, Federal Agency Representatives, and other industry representatives Public hearings – broadcast over the web NCVHS is listening closely to the needs of the industry – Good Job! http://ncvhs.hhs.gov/

Change Request Coordination ? 3 ANSI Standards Organizations 3 Data Content Committees DHHS / NCVHS Memorandum of Understanding X12 HL7 NCPDP NUCC NUBC DeCC Organizations mentioned in the legislation: 3 Standard Setting Organizations (SSO) 3 Data Content Committees (DCC) DHHS / NCVHS Concern over coordination, consistency, confusion to the industry MOU to define process for IG changes DHHS NCVHS

Implementation Guide / Data Content Change Request Web Request Form Work Request Tracking System http://www.hipaa-dsmo.org X12 HL7 NCPDP Approved Changes X12 HL7 NCPDP NUBC NUCC DeCC 90 Days to develop organizational Recommendation (45 Day Extension If Needed) X12 HL7 NCPDP NUBC NUCC DeCC 10 Business Days to Express Interest MOU established www.hipaa-dsmo.org Change Request System (CRS) Frequently Asked Questions (FAQ) data base Change Request (CR) Process Complete CR online or via paper (which you must download from the web) No later than 5th business day CR are sent to DSMO 10 Business days to express interest in change request (at least 1 organization must express interest) Organizations that express interest are called Collaborating Organizations – CO) The CO has 90 days to develop their Recommendation (+45 days if extension is needed) 2/3 vote of the CO needed to approve CR CO or Requestor can appeal decision of the CO (no one else can appeal) If approved CR is passed to the SSO to incorporate change into IG

Requesting A Change Choose the Implementation Guide State the Business Case for Change Request Provide a suggested change to meet Business Case External Code List Changes IG Appendix C – Code List Maintainers Changes are linked to a specific Implementation Guide Business case for change must be completed Provide a suggested change (technical or not) to meet the business case DO NOT REQUEST CHANGES TO EXTERNAL CODES referenced within the IG Request these changes of the organizations mentioned in Appendix C who maintains the code list

MOU Guiding Principals Public Access – Single Point of Entry Timely Review of Change Requests Cooperation and Communications Consider All Viewpoints Evaluate Impact of Change Requests Maintain a National Perspective Conform to Legislation and Regulatroy Process Any person or organization shall have the opportunity to submit a HIPAA Change Request and that there be a single consistent point of entry or process to request a change. The organizations agree to establish or maintain a methodology or process that ensures timely reviews and responses to all HIPAA Change Requests. Since the Secretary can promulgate new or revised HIPAA rules no more frequently than once a year, each organization's process should be designed to work within that time frame. The organizations agree to cooperate and communicate with one another as each organization looks at new transactions, changes in technology, or changes in the health care industry. The process allows for input and consideration of various viewpoints from health plans, providers and other entities involved in, or affected by, the HIPAA transaction rules. The organizations agree to consider the overall impact of the HIPAA Change Request on all the HIPAA transactions. While a request may seek a change to one transaction, it is possible that the change could have an effect on other transactions. The organizations agree to maintain a national perspective in satisfying the business needs of the health care industry while fostering administrative simplification. All changes recommended shall be consistent with HIPAA statutory and regulatory provisions.  

Next Steps… Annual DSMO Report to NCVHS - Recommendations NCVHS Review & Recommendations to HHS HHS Initiate the Federal Regulatory Process Draft NPRM NPRM Internal Clearance Publish NPRM – Federal Register Public Comment Period (30 – 60 days) Response to Comments Draft Final Rule Final Rule Internal Clearance Publish Final Rule – Federal Register 30-60 day Congressional Review Period Final Rule Includes the compliance date Cannot be less than 180 days Review the steps and the fact this alone will guarantee changes will not occur more frequently than once per year.

SUMMARY Process and timeline for IG Changes Frequently Asked Data Base Participate! Questions Gary Beatty Chair: X12N Insurance Subcommittee gmb803@earthlink.net