Tom Wilder Vice President, Private Market Regulation
American Association of Health Plans
1129 Twentieth Street, NW, Suite 600
Washington, DC 20036-3421
(202) 778-3255
twilder@aahp.org
Good morning. My name is Tom Wilder and I am Vice President, Private Market Regulation for the American Association of Health Plans (AAHP). AAHP would like to thank the National Committee on Vital and Health Statistics' Subcommittee on Standards and Security for the opportunity to discuss the efforts of our member health plans to implement the electronic transactions and code sets standards established pursuant to the Health Insurance Portability and Accountability Act (HIPAA).
AAHP is the nation's principal association of health plans, representing more than 1,000 plans that arrange health coverage for approximately 170 million Americans nationwide. Our member plans include health maintenance organizations (HMOs), preferred provider organizations (PPOs), and other similar health plans. AAHP's member health plans are subject to the HIPAA standards for electronic transactions and code sets that will go into effect October 16, 2003.
AAHP strongly supports the principles of administrative simplification established by the Health Insurance Portability and Accountability Act. As our health care system becomes more dependent on data automation, the need for clear, uniform standards is readily apparent. AAHP believes that uniform standards for electronic health care transactions will improve the quality and efficiency of a number of health care operations.
AAHP's members are working diligently to prepare for the October 16, 2003 compliance date of the HIPAA transactions and code sets rule and have allocated significant resources in their implementation efforts. Our members are concerned, however, that some other segments of the health care community may not be fully prepared to send and accept transactions that are "HIPAA compliant" by the rule's compliance date.
AAHP urges HHS to increase its efforts to assist covered entities with their implementation of the HIPAA transactions and code sets rule and development of any contingency plans. Contingency planning is a useful tool for covered entities and their business partners to determine what has to be done in order to transition from their current business systems to the new HIPAA requirements.
HHS' efforts should be undertaken without postponing the compliance date of the transactions and code sets rule. While a number of covered entities may need to be given some flexibility to reach full compliance with the rule, the goals and time frames established by the transactions and code sets rule should not be jeopardized. The benefits of the HIPAA standards should not be delayed for those covered entities that will be ready October 16, 2003 to conduct HIPAA compliant transactions.
In conclusion, AAHP does not support a delay of the compliance date of the transactions and code sets rule, but we recognize that some covered entities may require additional help to implement the rule. AAHP asks HHS to take a more active role in assisting health plans, health care providers, and health care clearinghouse with their compliance efforts. We also recommend that HHS consider appropriate contingency planning for those covered entities that anticipate they will not be fully ready to implement the HIPAA transactions and code sets rule on October 16, 2003. AAHP and its member health plans are ready to assist with these efforts.