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>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...." |
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"...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." |
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>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." |
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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 |
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Copyright © 2003, Alan S. Goldberg, Washington, DC, All Rights
Reserved