HIPAA's temporary reprieve.

As you might have heard, the Centers for Medicare and Medicaid Services (CMS) announced in September the implementation of a contingency plan for healthcare facilities struggling to meet the October 16, 2003, deadline for provider and payer compliance with HIPAA's electronic transactions and code sets provisions. The decision to accept noncompliant electronic transactions for a while was based on statistics indicating that low numbers of compliant claims would be submitted as of October 16.

This decision has had broad--and important--ramifications. Since CMS released its statement, Blue Cross and Blue Shield announced that the nation's 42 Blue Cross and Blue Shield plans will a[so have HIPAA contingency plans under which they will accept existing claims-submission formats during a transition period after the deadline. The contingency plans will allow providers to maintain their cash flow during the transition and minimize the number of paper claims submitted. While each Blues plan will determine the length of its contingency plan, it is likely that many private health insurance plans will follow CMS policy.

What does this mean to facility operations? After CMS's announcement, the Healthcare Information and Management Systems Society (HIMSS), the nation's major professional healthcare information technology association, issued recommendations:

* Maintain your current contingency plan. Do not assume that there will be a lengthy reprieve.

* Continue testing, and obtain firm testing dates from all trading partners.

* Review and follow your contingency plan for claim submissions to Medicare and Medicaid, if you have not successfully tested with CMS to date.

* Contact other payers in addition to CMS to determine their readiness and whether they will accept noncompliant transactions.

* Document everything you have done thus far to become compliant, especially your specifics in contingency planning.

* Consider contracting with a third-party vendor that specializes in HIPAA compliance testing and certification to assist you with determining whether your transactions or those of your trading partners are compliant.

* Keep a close watch for future CMS announcements regarding how long the contingency plan will remain in effect; check www.cms.gov/hipaa/hipaa2 regularly.

* Monitor your benchmarks for HIPAA compliance readiness at www.himss.org/asp/industry_research.asp.

In short, implementation of CMS's and other payers' contingency plans will ensure that your healthcare claims will continue to be processed after the October 16 deadline. But make sure you continue to make necessary changes to electronic claims procedures, as recommended by HIMSS, to meet compliance requirements. It is sale to assume that these will be enforced in the not-too-distant future.

Malcolm H. Morrison, PhD, is president/CEO of Morrison Informatics, Inc., an information technology and data analysis consulting company in Mechanicsburg, Pennsylvania. For further information, phone [phone] of e-mail [e-mail].

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