[ Thursday, October 09, 2003 ]


HHS Contingency Plan = No Deadline? No way.

I've gotten an e-mail or two from some folks asking, basically, whether the HHS contingency plan means that the October 16 deadline is gone. Some others have asked when the new deadline is, now that HHS issued its contingency plan and has said you don't have to have your transactions in X12 format by then.

Folks, if you think the fact that HHS agreed to the contingency plan means that the deadline is gone, you're wrong. All the contingency plan means is that, if you've got a good story to tell and can show that you're doing the best you can to get compliant, HHS probably won't whip you too bad for missing the October 16 deadline. Basically, CMS doesn't have to accept medicare/medicaid claims that are not in X12 format after October 16; however, since HHS knows that there are many folks that won't have made the conversion in time, they are agreeing that they MAY still pay non-X12 claims after October 16. But they don't have to; if you just didn't feel like making the switch, don't be surprised if your claims get denied, either currently or retrospectively.

There is no "new deadline." The deadline is still October 16. In fact, if you didn't ask for the extension, you're deadline was October 16 of last year! But HHS is just saying that they won't be hard-asses with folks who couldn't get there despite their own best efforts.

What to do? If you can get to X12 in the next week, do so. If you can't, keep on keepin' on. Do what you can, and hope you're not the one HHS decides to make into an "object lesson," as Dave Robicheaux would say. You still need to get there, and if that means beating on your vendors, payors, trading partners, whomever, then get to it.

Ultimately, everyone has got to get there. While you won't necessarily get the best seats, there's no downside to getting there before the crowd.

Jeff [3:53 PM]

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