"Administrative simplification" is something we all want. But the changes
required to achieve the administrative simplification called for under HIPAA
will be anything but simple.
Physicians have less than six months to prepare for compliance
with HIPAA’s electronic transactions and code-sets rule, which standardizes
claims submission, processing, and payment. This standardization will do
for health care what it did for the banking industry not too long ago. Many of
us will remember when we had to physically go to the bank to make a transaction.
We had to be there during banking hours–and those hours were short. Now we bank
from home and we can get cash at any time of day from the corner ATM. The
convenience of banking transactions was the outcome of data standardization and
electronic communications.
HIPAA lays the groundwork for a similar
data revolution in health care. Imagine being able to transmit a claim, receive an automatic, electronic
confirmation that the claim was received by the payer, and track that claim
through the payer’s system without having to pick
up a phone. Imagine electronically confirming insurance eligibility for your patients. Imagine being able
to request and receive authorizations online. Imagine being able to
receive wire transfers of payments and the automatic posting of remittances to
your billing system.
Streamlining of data should be a significant benefit to the business aspects
of the practice. The present, however, is filled with complex details, thorny
choices, unanticipated expenses, and confusion. The decisions will be difficult.
The following are 10 steps you can take to get ready to send HIPAA compliant
claims by the October 16 deadline.
Steps to Take
1. Determine if you are covered by HIPAA. Do you electronically conduct, or does a third party
or clearinghouse conduct on your behalf, any of the following
transactions?
- claims or encounter information
- payment or remittance advice
- claims status inquiry or response
- eligibility inquiry or response
- referral authorization inquiry or response
If you
answered 'no,' there is one more test to determine if you are covered by
HIPAA. If you provide services to Medicare beneficiaries and your practice has 10
or more FTEs (including physicians), you must bill Medicare electronically beginning October 16, making
you a covered entity.
If you are not a covered entity, you do not have to pursue the following
HIPAA readiness tests unless you choose to do so.
2. Identify which transactions you currently perform (or desire to perform) electronically.
3. Find out if your software (or the software of your billing service) is ready
for HIPAA transactions. Physicians or their billing services must be ready to transmit claims
in the standard format by October 16. Failure to do so will likely result in
impaired cash flow.
Note: CMA has created sample letters that
member-physicians can use to begin analyzing their HIPAA upgrade needs with
their vendors and billing services. Click
here for more information.
4. If your software (or billing service’s software) is
not already able to transmit claims in the HIPAA standard format, find out from your software vendor if and when
they will produce a HIPAA-compliant upgrade. Vendors should already be in the testing phase so
that their physicians customers will have enough time to install and familiarize themselves with the new
software. Ask the vendor if it will seek certification by one of the certifying
bodies that assure systems have been properly tested.
Note: CMA will soon post a list of certifying bodies
in the HIPAA Resource Center.
5. If your software/billing service vendor has not begun testing or does not
plan to seek certification, you need to examine alternatives to assure you can
transmit compliant claims. Contact your clearinghouse to learn if they can
accept the current transactions from your software/billing service and perform
the mapping functions to make them compliant.
6. If your software vendor tells you that you need an upgrade, ask them if the upgrade will be sufficient to
transmit the standard format directly to the payer or if you will still
need to use a clearinghouse to properly prepare the claim. Before you authorize them
to proceed, find out how much the solution costs (upgrade and any
required clearinghouse fees) and whether the vendor can install the upgrade and train your
staff before the October 16 deadline.
7. If the costs identified are higher than you believe
reasonable, or the vendor cannot assure completion of the installation by
October 16, return to step 5 and check other clearinghouses. If you enter into a
new or updated contract arrangement with a billing service or clearinghouse, do not presume the terms
of the contract are the same as before. Review each contract and make
sure it is not more onerous.
Note: Click here for a list of
clearinghouses and vendors certified by Medicare in California. CMA is also
looking into the possibility of encouraging additional clearinghouses to enter
the CA market and provide discounts to CMA members.
8. If you cannot find a clearinghouse that can accept
your software’s output and convert it to the standard format before October 16,
you have three options: secure services from a billing service who can
demonstrate ability to transmit compliant claims; purchase new software that is
HIPAA compliant (although as a practical matter, it may be difficult to
transition to a new practice management system by the deadline); or convert to
paper filing for non-Medicare payers and bill Medicare using the free electronic
software Medicare provides, downloadable at http://www.medicarenhic.com/edi/EDIhome.htm.
9. If you opt to bill on paper, take steps to assure you have an adequate
supply of forms on hand. There may be a surge in demand for 1500s as the
deadline approaches.
10. If you are not satisfied
with the solutions you have available, use the most acceptable option as a
transition and continue to explore better alternatives. Choices will get better as
vendors and services adapt to the new rules and the better options become more
well known.
Note: CMA is also looking into practice management
solutions that are HIPAA compliant and provide discounts to CMA
members.