HIPAA SUMMIT AUDIOCONFERENCE
HIPAA ADMINISTRATIVE SIMPLIFICATION TCS - 8/14/03
Alan S. Goldberg Faculty Materials - For Educational Purposes Only
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>Alan S. Goldberg Article - Health Lawyers Weekly - July 25, 2003 - HIPAA Administrative Simplification, Transactions and Data Code Sets: Will Health Care As We Know It Survive?

>CMS Guidance of July 24, 2003 - Compliance

>MCS - March 14, 2003 FROM: Director Survey and Certification Group - Review of Protected Health Information and Applicability of Business Associate Agreements Under the Health Insurance Portability and Accountability Act (HIPAA) for the Purposes of Survey and Certification
>CMS - Program Memorandum Department of Health & Human Services (DHHS) Intermediaries/Carriers Centers for Medicare & Medicaid Services (CMS) Transmittal AB-03-034 Date: FEBRUARY 28, 2003 - Medicare Fee for Service Contractor Guidance on the HIPAA Privacy Rule
>Thomas A. Scully, CMS Administrator, Letter of July 18, 2003 to Medicare Providers
"Effective October 16, 2003, all electronic transactions covered by HIPAA must comply with these standards for format and content...."
>ACLA, AHCA, AHA, AMA, Premier, Inc., VHA
letter of July 1, 2003 to Secretary Thompson
"...We believe it is essential for HHS to take the following steps to prevent the impending 'train wreck' on October 16th [2003]...."
>NCVHS letter of June 25, 2003 to Secretary Thompson
"...Despite the diversity of representation of the groups who provided testimony and letters, there was overall agreement that the Federal government should permit operational compliance, as opposed to strict technical compliance, for a limited period of time following the October 16 deadline. This would allow for the necessary trading partner testing to take place across the industry, as well as mitigate any potential unintended adverse consequences to provider cash flow and patient care...."
>American Association of Health Plans letter of June 6, 2003 to Tom Scully, Administrator, CMS, regarding TCS rule compliance
>American Hospital Association letter of April 17, 2003 to Tom Scully, Administrator, CMS, regarding enforcement
"...AAHP does not support a delay in the October 16, 2003 compliance date of the TCS rule. An implementation delay could penalize those covered entities that have invested the time, resources and commitment to implement the HIPAA standards. At the same time, we do believe that CMS should provide a smooth transition from the current electronic transaction standards used by health plans, health care providers, and health care clearinghouses to the standards that will be required when the TCS rule goes into effect. We urge CMS to adopt the WEDI recommendations to achieve this goal. We appreciate your work to simplify administrative procedures and we are eager to work...."
>WEDI letter of April 15, 2003 to CMS
"The issue at hand is how does the industry make the short-term transition from its current state to a successful implementation, given a substantial degree of noncompliance in October 2003, and thus avoid the so-called train wreck that will result from reversion to paper claims or stoppage of cash (payment) flows."
>AHA letter of May 19, 2003 to CMS
"...[W]e propose development of a system-wide implementation plan that clearly outlines remedial actions that every health plan must take to ensure that an adequate level of cash flows to hospitals is maintained as the field transitions to HIPAA standardized claims."
>American Hospital Association letter of June 16, 2003 to CMS regarding civil monetary penalties, health care claims, & privacy
"...We look forward to working with you to make sure that the efforts related to HIPAA enforcemennt appropriately encourage improvements in hospitals' compliance programs...."
American Hospital Association letter of June 25, 2003 to Secretary Thompson regarding transactions codes"...At the TCS implementation date approaches, hospitals are growing increasingly concerned about the potential for disruption in the current claims submission and payment cycles that might result from poor, improper or incomplete implementation of the HIPAA standard transactions...."
HIPAA Terms: An Annotated Glossary
A glossary of Administrative Simplification terms from certain of the rules promulgated under the
Health Insurance Portability and Accountability Act of 1996 (HIPAA)
By Alan S. Goldberg, Esq., Steven J. Snyder, Esq., Bradley G. Allen, Esq., and Elizabeth C. Myers, Esq.
"This glossary of Administrative Simplification terms from certain of the rules promulgated under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) is intended to provide an easily accessible educational reference for understanding the Transactions and Code Sets Rule, the Privacy Rule, and the Security Rule. In addition, this title includes a copy of portions of the 1998 proposed Security Rule (63 Fed. Reg. 43,242, 43,271-77 [August 12, 1998]). Although not contained in any final rule, this material provides definitions of terms, a list of acronyms, and a bibliography that continue to be useful to the practitioner working with HIPAA."
published June 2003 by American Health Lawyers Association
*Alan S. Goldberg is a member of
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Copyright © 2003, Alan S. Goldberg, Washington, DC, All Rights Reserved