[ Tuesday, October 21, 2003 ]
Here's an interesting article
from the New Mexico Business Weekly on the HHS contingency plan. The article says that the October 16 deadline was "extended."
Let me note again that the Transaction and Code Sets deadline of October 16 was not extended, removed, deleted, revised, or any such thing. It is still there. As of last Thursday, if you submit or receive electronic transactions, you should only be submitting or receiving them in HIPAA compliant, ANSI ASC X12 format (either personally or through a clearinghouse).
The HHS contingency plan will allow CMS to continue to accept non-compliant electronic claims, but only if the entity submitting the electronic claim has a good reason for not being ready. Really, it is not a delay in the enforceability of HIPAA; it is a delay in the enforcement of HIPAA TCS standards (or more appropriately, a delay in the punishment of offenders for violating the HIPAA TCS standards). Remember, the October 16, 2003 deadline was/is only applicable to covered entities that filed for the extension before October 15, 2002. If you are a covered entity and did not file for an extension last year, you have already been out of compliance for a year.
If you haven't made any efforts to migrate to HIPAA-compliant electronic transactions, you better get to it. The HHS contingency plan isn't a blank check, and HHS can hold you responsible if HHS determines that you haven't taken serious efforts at compliance with TCS.
Jeff [8:57 AM]
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