My name is Bob Owens. I am the associate executive director of information technology and Chief Information Officer for the American Dental Association (ADA). It is my pleasure to appear today on behalf of the ADA before the Subcommittee on Health Data Needs, Standards, and Security of the National Committee on Vital and Health Statistics (NCVHS). The following points summarize our statement and recommendations as a content expert on the subject of claims attachments.
As Dr. Rose presented to you yesterday, the ADA has as one of its strategic goals, the elimination of the need for claims attachments. Approximately 30% of dentists who are capable of accessing an external data network submit claims electronically. Reasons given for this low percentage include lack of equipment to access a network; cost of submitting claims; and third-party payers inability to accept claims electronically.
The fact is claims attachments that do not assist the adjudication of the dental claim merely add to the cost of filing claims. As we work toward the elimination of claim attachments, Payers should be required to pay all claims using a uniform adjudication process. If attachments are required by the payers, requests should be specific and limited to one time and payment should be prompt and without exception once attachments are provided.
If attachments are required for dental claims it may result in a significant delay in reaching the goal of HIPAA administrative simplification through the use of electronic technology. For example, if X-Rays were to become a required communication in any number, the current payer or provider infrastructure does not support it. As a result many claims that could be sent electronically are reduced to paper. The payer and provider vendors have not implemented standards, or it has proven to be too expensive.
The ADA has become the source of dental data for the profession. We have done this through a variety of means. Some of these include surveys, focused clinical studies and electronic capture of data sets. The ADA believes the best source for Public health and other similar information requirements is the existing claim transaction for the short term.
However, to improve the available pool of data, the long-term plan should be to use clinical medical record software as it matures. The ADA has made significant progress toward developing a health record. We anticipate that as this record is implemented that it will become the best source for clinically related dental information. We also believe that the implementation of this record will be driven by the clinical need in the dental practice and not claims adjudication.
Since clinical, claims and several other types of dental patient data is created by or generated from the provider, providers should have the lead in determining the data content for all information relating to dentistry and how it is used. Privacy and confidentiality of patient data should take precedent over other possible uses of this data.
The ADA is uniquely positioned as both a professional organization representing 74% of practicing dentists and a national and international ANSI accredited standards organization. The ADA has been successful in establishing organizations that provide industry access, appropriate representation, timely development and cross discipline coordination for all of organized dentistry’s needs for information content. Below is a list of some of the current ADA activities:
It is our experience that to develop meaningful standards and business processes, one must begin with those most responsible for creating the information. In addition, one must have an organization that is flexible enough to meet the changing demands while maintaining the principle of stewardship.
We believe the ADA’s proven ability to develop content puts us in the best position to facilitate content development activities. Our responsibility as the steward of organized dentistry requires it.
We thank you for the opportunity to present before you and look forward to working with you on dental data content matters.