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CMSRulemakingCMS-2008-0101

Health Insurance Reform; Modifications to the Health Insurance Portability and Accountability Act (HIPAA) Electronic Transaction Standards

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American Health Care Association (AHCA/NCAL) filings
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American Health Care Association (AHCA/NCAL) filed 1 comment on this docket between Oct 22, 2008 and Oct 22, 2008. 33 other organizations filed here. The comment window closed 6489d ago.

What American Health Care Association (AHCA/NCAL) filed (1)

Oct 22, 2008· DC-American Health Care Association· CMS-2008-0101-0077

October 21, 2008 Kerry N. Weems, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-0009-P P.O. Box 8014 Baltimore, MD 21244-1850 Re:CMS-0009-P – "Health Insurance Reform; Modifications to the Health Insurance Portability and Accountability Act (HIPAA) Electronic Transaction Standards; Proposed Rule," 73 Fed. Reg. 49742 (Aug. 22, 2008) Dear Mr. Weems: The American Health Care Association (AHCA) appreciates the opportunity to provide comments to the U.S. Department Health and Human Services (HHS), Office of the Secretary, on the proposed rule, "Health Insurance Reform; Modifications to the Health Insurance Portability and Accountability Act (HIPAA) Electronic Transaction Standards; Proposed Rule" (73 Fed. Reg. 49742 [Aug. 22, 2008]). AHCA represents more than 10,000 non-profit and for-profit providers dedicated to continuous improvement in the delivery of professional and compassionate care for our nation's frail, elderly and disabled citizens who live in long term care facilities, including nursing facilities, assisted living residences and homes for individuals with developmental disabilities. AHCA understands that HHS is proposing the adoption of the updated X12 electronic transaction standard, Version 5010, as an essential component to the agency's proposed rule, "HIPAA Administrative Simplification; Modification to Medical Data Code Set Standards to Adopt ICD-10-CM and ICD-10-PCS: Proposed Rule." We are supportive of the transition to Version 5010; however, we are asking the agency to correct the small technical omission of the "assessment date" field, which is important only for long term care providers, and results in a myriad of problems. All Medicare- and Medicaid-certified nursing facilities are required, under the federal law, to fill out a Minimum Data Set (MDS) 2.0 form within 14 days of admission to begin the screening and care planning process for their residents. After the initial assessment, follow-up assessments are required and continue on a scheduled basis. This assessment data is critical and drives Medicare Part A payment, publicly reported quality measures, care planning, survey citations and, in some states, Medicaid case mix payment systems. AHCA strongly believes that this correction must occur prior to the release of the final Version 5010. AHCA also is concerned that with the adoption of the updated X12 electronic transaction standard, Version 5010,, the Centers for Medicare & Medicaid Services (CMS) continues to refine its over-arching IT strategy, with multiple iterations of incremental changes that make it difficult for long term care providers to adequately implement these changes. Further, there are significant cost consequences with each change. AHCA encourages CMS to look at its overall plan, and schedule changes in an orderly fashion, allowing the agency the time to verify the accuracy of its instructions, and giving providers the time to absorb and train staff. Thank you for your consideration of these matters. Sincerely, Bruce Yarwood President and CEO cc:Barbara Baylis, AHCA Clinical Practice Committee Chair John Barber, AHCA Finance Committee Chair Chuck Goux, AHCA Health Information Technology Committee Chair

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Abstract

This rule proposes to adopt updated versions of the standards for electronic transactions originally adopted in the regulations entitled, “Health Insurance Reform: Standards for Electronic Transactions,” published in the Federal Register on August 17, 2000 (65 FR 50312), which implemented some of the requirements of the Administrative Simplification subtitle of the Health Insurance Portability and Accountability Act of 1996 (HIPAA). These standards were modified in our rule entitled, “Health Insurance Reform: Modifications to Electronic Data Transaction Standards and Code Sets,” published in the Federal Register on February 20, 2003. This rule also proposes the adoption of a transaction standard for Medicaid Pharmacy Subrogation. In addition, this rule proposes to adopt two standards for billing retail pharmacy supplies and professional services, and to clarify who the “senders” and “receivers” are in the descriptions of certain transactions.

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Co-filers (33)

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