Testing for Successful Deployment: Roundtable Discussion HIPAA COW Spring Conference April 8, 2011

Rick Hammes, WEA Trust Greg Margrett, Ingenix Barb Pretasky, Franciscan Skemp Healthcare

What is Level I Testing and Compliance? Level I testing is the period when covered entities perform all of their internal readiness activities to prepare for testing the new versions of the standards with their trading partners. Level I Compliance means a covered entity can create and receive compliant transactions that result from the completion of all internal activities and testing. Covered entities should have been prepared to meet Level I compliance by December 31, 2010.

What is Level II Testing and Compliance? Level II testing activities involves external testing with trading partners and should begin by January 1, However, covered entities must be compliant with Level I activities before they can prepare for Level II testing. Level II compliance means that a covered entity has completed end-to- end testing with each of its trading partners, and is able to operate in production mode with versions 5010 and D.O. Covered entities must be Level II compliant by January 2012.

What should already be done? You should have the Technical Report Type 3 (TR3s) from Washington Publishing Company ( these are the “implementation guides” for System upgrades should either be completed or underway. If not, you should already know when your vendor(s) will be ready for 5010 and when upgrades will be available. Your list of most-important payers and their testing requirements and methodologies should be complete. You should know when your clearinghouse(s) will be testing with your most important payers, and if your data can be included for testing.

Are you communicating? You should be! Identify internal and external stakeholders and trading partners and engage them in the process. Coordinate and manage direct connection with trading partners throughout the transition. Contact application vendors to learn of their delivery schedule for the system upgrade(s). Contact clearinghouse vendors to learn of their testing schedule for payers of key interest to the provider. Contact key payers to learn of EDI exchange modifications (e.g., will a new Submitter ID be required for the 5010 version versus the current 4010 version; will telecommunication connectivity changes be required).

Are you training? You should be! Provide training for business and technical staff on the changes identified through your 5010 gap analysis. Training should focus on the following: Understanding the transaction changes. Learning the practice management system (software) changes. Learning new workflow processes.

DON’T WAIT!!! There is only a little over 75% of the year left in which to test with your trading partners. If you go direct to any trading partners, you MUST test with them! If you use a clearinghouse or other intermediary, you MUST test with them! Even providers that have non-ANSI systems must still test with their vendor and/or clearinghouse to ensure that their data that ultimately reaches the payer is compliant in 5010 format!

Things you can do to help your testing work Perform some kind of HIPAA validation on your test files before sending them to your trading partners – don’t use your partners as a validation tool! Verify if your trading partners are using/accepting the 5010 errata version for testing; if not, will they require it in the future? Remember that there are changes in 5010 that will require you to alter how you may be doing things today: PO Boxes and Lock Box Addresses are not allowed in the Billing Provider loop (2010AA); only a physical address is allowed. You cannot combine both a physical address and a PO Box/Lock Box Address in the Billing Provider loop (2010AA).

Things you can do to help your testing work If you have multiple locations that get paid to a Lock Box or PO Box, enter the physical building address in the Billing Loop and enter the PO Box or Lock Box in the Pay To Loop. If you do additional sub-parting of your locations and don't put the PO Box or Lock Box in the Pay To Loop, you will get payments sent to each location that is in the billing loop.

Provider concerns and experiences Payer concerns and experience Vendor concerns and experiences What have you experienced so far?

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