| Organization Name: X12N Insurance Subcommittee |
| Gary Beatty |
Members of the Subcommittee, my name is Gary Beatty, Chair of the X12N Insurance Subcommittee. I would like to thank you for this opportunity to testify today regarding the X12N Implementation Guides adopted under the transaction standards requirements of the Health Insurance Portability and Accountability Act of 1996 and our commitment toward continued maintenance and revisions to these Implementation Guides to meet the needs of the healthcare industry. X12N has documented its development and maintenance process within the “X12N Implementation Guide Handbook” (http://www.wpc-edi.com/transfer/handbook.pdf) and the memorandum of understanding adopted by the Data Standards Maintenance Organizations (DSMO).
As the healthcare industry continues to prepare for compliance and implementation of the transaction standards, X12N has received comments and change requests to the HIPAA implementation guides, either directly or via the Change Request System (CRS) established by the DSMOs. X12N welcomes these change requests as opportunities to improve the Implementation Guides and gain additional industry input. Unfortunately this also means some organizations are looking at the Implementation Guides for the first time, or seriously for the first time. For a time X12N referred to these items as “Errata” (which was an incorrect classification by definition). At the last X12N meeting these items were reclassified as “Corrections” to the Implementation Guides. DHHS has categorized changes to the HIPAA Implementation Guides as either “Maintenance” or “Modifications” as described earlier by Margaret & Maria. X12N’s Corrections to the HIPAA implementation guides can be either modifications or maintenance.
The transaction final rule contains a clause that allows the Secretary of Health and Human Services to adopt modifications to the transaction standards if necessary for the industry to comply with the regulation anytime during the first 12 months. In response several initiatives have begun including:
Regardless of how efficient the DSMO and SSO make their development processes through either the fast track or normal process, the healthcare industry is still bound by the federal rule making process, which has proved to be a very slow process. In order to adopt these Addendums under HIPAA, the DHHS would have go through the following steps and timeline:
| June 2001 | X12N will complete the “Addendums” for consideration in an Interim Final Rule to the already published HIPAA Implementation Guides. |
| February 2002 | DHHS publishes “Interim Final Rule” with comment period |
| April 2002 | Effective date for an “Interim Final Rule” (after 60 Congressional comment period) and if no substantive comments were received. |
| October 2002 | End of 180-day minimum implementation timeline to coincide with the original implementation timeline (If 180 day minimum is acceptable). |
| April 2003 | Next opportunity to change the transaction standards (12 months), which had Addendums, adopted under the interim final rule. |
If no Addendums are adopted for a HIPAA Implementation Guide, the next version can be adopted anytime after October 16, 2001. It is also unclear when the 12 months starts for the next version, is it the effective date of the rule or after the implementation timeframe is completed (180 day minimum).
The HIPAA Implementation Guides are not perfect. There are still healthcare stakeholders that do not even know (or want to believe) they will be affected by HIPAA. X12N is working on identifying those changes that are necessary for the industry to comply with the regulations. However we need to deal with the change management process we are bound by and how, if possible it can be adapted to better meet the needs of the healthcare industry.
I look forward to your questions and thank you again for this opportunity to testify today.
Gary Beatty
Chair X12N Insurance Subcommittee