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HIPAA Transactions: 10 Steps to Compliance

HIPAA's administrative simplification requirements will
revolutionize the business of health care. Are you ready
to take the next hurdle?

by Nileen Verbeten,
Vice President,
CMA Center for Economic Services

"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.

 

   
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