AAFP, other organizations want help on TCS implementation -- August 2003 -- FP Report

AAFP, other organizations want help on TCS implementation

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The AAFP has been fighting for fairness for its members ever since the Health Insurance Portability and Accountability Act passed Congress.

The latest advocacy effort was in the form of a hand-delivered letter to HHS Secretary Tommy Thompson on June 30. The AAFP joined 35 other medical organizations in a chorus of rising concerns about the health industry's readiness for the Oct. 16 compliance date for the HIPAA transactions and code sets standards.

"The possible rejection of nonstandard electronic transaction and the resulting reversion to paper transaction could result in a major disruption of payment flow to providers under Medicare, Medicaid and private sector health plans," said the letter.

The letter expressed concern about the adverse impact that the disruption in payment could have on the delivery of quality health care across the country. Zeroing in on the hazard to health care, the letter continued, "We believe the federal government must act immediately to avert this possibility by developing and disseminating a comprehensive contingency plan to circumvent any negative impact associated with the Oct. 16 deadline."

The letter presented Thompson with this stark scenario: "As of today, only 3 1/2 months remain before the deadline, and relatively few providers have successfully completed external testing. Providers that have attempted to test are finding the process difficult and confusing. In addition, we anticipate that just prior to Oct. 16, a large percentage of providers will attempt to initiate testing. This will result in a substantial number not being able to complete this process in time to meet the deadline."

The letter suggested three contingency plans:

Plan one: A compliant covered entity should be permitted to accept a HIPAA standard transaction that may not contain all required data content elements, if these transactions can otherwise be processed to completion by the health plan.
Plan two: A compliant covered entity should be permitted to continue accepting proprietary (nonstandard) transactions for a brief transition period.
Plan three: Noncompliant health plans should be given an incentive to offer interim payments to their provider clients.

In addition, the federal government should "facilitate this process by providing clarification and direction on critical issues," said the letter to HHS. The letter suggested some issues that warrant "fundamental directives" from Thompson, including assuring health plans that they will not be considered noncompliant if they accept claims from providers who are in good faith trying to achieve compliance; encouraging health plans to communicate to provider clients specific testing dates and procedures to send test transactions; and asking health plans to develop contingency plans to handle the expected increase in paper claims submissions as a temporary solution.

The medical organizations also asked HHS to "significantly expand its current education outreach campaign to providers."

"These proposals in no way suggest a delay in the implementation of the HIPAA standards. Rather, through our recommendations outlined in this letter, we seek to ensure that the migration to these new standards occurs as orderly as possible and prevents any interference in the delivery of health care," the letter concluded.

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