At Accredited Standards Committee X12's HIPAA Informational Forum in
Atlanta on 9/28/2005, the question was raised as to whether the closing
date for the Claims Attachments Notice of Proposed Rule Making (NPRM)
could be extended. One of the speakers, Lorraine Doo of CMS/OESS,
agreed to see if this was possible.

In a series of messages, Lorraine has responded to me in the
affirmative: there is precedent for extending the closing date for an
NPRM public comment period. Additionally, she reiterated that one of
the key purposes of the comment period is to obtain feedback on the 10
technical documents being proposed; not just the policies expressed in
the NPRM itself. CMS/OESS is very interested in receiving quality
technical feedback, and if extending the closing date will facilitate
this, they are quite willing to assist in this way.

For the industry to obtain a later closing date, CMS/OESS needs to
officially receive requests for a new date. These requests should be
submitted as comments to the NPRM as specified on page 55990 of the
NPRM, and should be submitted as soon as possible to allow maximum
working and notification time for any new closing date that might be
established.

[Feinberg notes: Requests should be specific as to a desired new
closing date, plus provide rationale (e.g., specific organizational
and/or evaluation impacts resulting from the newness of technical
materials, novelty of technical materials, quantity of technical
materials, complexity of technical materials, whatever). For reference,
X12N's public comment period on it's 2 named claims attachments
Implementation Guides ran from 12/05/2003 through 1/04/2004. I don't
believe HL7 ever had a public comment period similar to X12N's for their
8 documents -- their procedures don't work this way.]

Hope you find this message useful.

Dave Feinberg
Co-chair, X12N/TG3/WG3
HIPAA Implementation and Coordination
Rensis Corporation [A Consulting Company]
206-617-1717
DAFeinberg@...
Author of "Understanding HIPAA Communications"