QUESTION 1: What are your organization's expectations for the results of the Administrative Simplification standards requirements in the Health Insurance Portability and Accountability Act of 1996 (HIPAA)? In what ways will the outcome affect the members of your organization, both positively and negatively?
RESPONSE: If done correctly, the standards requirements in HIPAA could be greatly beneficial to members of our organization. Anything which could increase the use of common emergent standards such as X12 and HL7, which have become more or less universal for the clinical enterprise of university health care systems for financial and clinical data exchange, would help greatly. According to our surveys, more than 95% of our members adhere to standards like HL7 for the exchange of clinical data, X12 for the exchange of financial data, DICOM for images, NCPDP for pharmacy data, etc. Standards at the communications level would, we hope, at least embrace the best aspects of the internet so that our nation's universities can continue to harvest direct economic benefits from this technology.
Our expectation is that the Administrative Simplification standard requirements will result in cost savings by utilizing working and accepted standards in each domain. For example, it is probable that HCFA and others will require support for the UB92 and 1500 formats for quite some time into the future. Health Level Seven's Version 2.2 Standard, which currently supports the these federally required data sets, could be used to meet this requirement. Besides offering support for such reports, the Health Level Seven Standard provides healthcare providers such as hospitals and clinics, with the ability to consolidate patient billing information between computer systems, and the ability to electronically transfer medical records.
Health Level Seven is an ANSI accredited SDO that has gained market acceptance and wide spread use, not only within the U.S. but internationally in such countries as Canada, The Netherlands, Germany, Australia, New Zealand, Finland and Japan. International commerce in healthcare is an important and expanding business for academic health centers.
Selecting standards that do not have market acceptance will be detrimental to and most likely result in higher costs to all parties involved.
Finally, to exclude any standard that is now a significant part of the current suite of standards for our members would create significant and unnecessary financial burdens.
QUESTION 2: Does your organization have any concerns about the process being undertaken by the Department of Health and Human Services to carry out the Administrative Simplification requirements of this law? If so, what are those concerns and what suggestions do you have for improvements?
RESPONSE: Our members do have some concern with respect to the process. There is some question as to how fully the DHHS understands the issues. We would like to see that HL7 and other SDOs be given the opportunity to work directly with the departments (VA, HCFA) to present the full breadth of these standards. The Health Level Seven Standard provides a robust offering in terms of clinical data (both inpatient and outpatient) unmatched by most standards. We want to assure that this strength is fully understood and embraced.
We also have some concerns about the potentially stultifying effects of some privacy and security requirements upon the research and educational enterprises of our members. Assuring a healthy balance which both assures security and privacy for individuals and still allows the proper and unimpeded flow of research and educational information between researchers, teachers and students is a primary need.
QUESTION 3: What major problems are experienced by the members of your organization with the current transactions specified under the HIPAA? For generators of the data, how readily available is the information that you need to provide for the transactions and how meaningful is that information from a clinical perspective? For users of the data, are you receiving the information you need from the transactions to pay the bill, manage the care process, etc., and what is your perception of its quality?
RESPONSE: Our members are concerned that one of the major problems with the transactions currently specified under the HIPAA is that the boundaries are unclear. For example, it appears that a modest amount of clinical data is mixed in with charge (HCFA) requirements. It is our feeling that it would beneficial to clearly define clinical data as its own transaction domain properly separated but linked to financial data. Further, if clinical data can be fully separated from financial data as HL7 allows, it could greatly facilitate a number of cooperative enterprises between the government and the academic health centers, such as the data sharing of clinical data in NIH cooperative clinical trials.
QUESTION 4: How can the goal of administrative simplification best be achieved while meeting the business needs of all stakeholders?
RESPONSE: It is our feeling that this goal can best be achieved by utilizing a concert of existing and market-proven standards. We expect that a working and accepted standard will be selected for each domain.
Several standards such as HL7 work well because of their connectedness to the business needs of the stakeholders. Assuring that underlying any standard selected is a well-conceived and fully-demonstrated business model should be a requirement. Any standard proposed without such underpinnings could deter the success of HIPAA.