Re: When Electronic Claims Attachments May Be Sent

Under the currently proposed HIPAA Claims Attachments Notice of Proposed
Rule Making (NPRM), providers may only send electronic claims
attachments
-- in response to an explicit health care claims attachment
request from a health plan [a.k.a.,"solicited"],
or
-- when a health plan has issued advance instructions permitting
an electronic health care claims attachment to accompany the
associated electronic claim [a.k.a., "unsolicited"].

{source: Federal Register, Volume 70, Number 184, 23 September 2005,
page 56024, column 3; specifically, proposed 45 CFR
§162.1920 (a) and (e) }


It would be a service to our industry if you and your colleagues
would take just a few minutes and respond to the following few questions
about your present approach for sending claims attachments.

_____

(1) When does your organization presently send claims attachments?
[Please flag all that apply. If possible, a percentage or other volume
indicator for each option would prove even more valuable.]
(a) At the same time and 'stapled' to the applicable claim
(b) At the same time, but separate from the applicable claim
(c) Subsequent to sending the applicable claim when your
organization determines it's appropriate
(d) Subsequent to sending the applicable claim only when
requested by a health plan
_____

(2) What mechanisms does your organization presently use to send
claims attachments? [Please flag all that apply. If possible, a
percentage or other volume indicator for each option would prove even
more valuable.]
(a) Printed paper sent by mail, courier, package carrier, etc.
(b) Printed paper sent by facsimile
(c) Electronic paper; i.e., text, word processor, scanned files
that are replicas of printed paper, sent on physically transportable
electronic media by mail, courier, package carrier, etc.
(d) Electronic paper; i.e., text, word processor, scanned files
that are replicas of printed paper, sent by facsimile
(e) Electronic paper; i.e., text, word processor, scanned files
that are replicas of printed paper, sent by computer-to-computer
communications; e.g., file transfer program, e-mail / e-mail attachment,
posting on neutral intermediary system
(f) Non-paper organized electronic files sent by
computer-to-computer communications; e.g., file transfer program,
e-mail / e-mail attachment, posting on neutral intermediary system
(g) other.
_____

(3) If you have some additional time, please matrix the answers for
questions 1 and 2 to indicate 'when' claims attachments are sent for
each 'sending mechanism'.
_____

(4) Which parts of the approach proposed in the NPRM are acceptable
given that different health plans often have differing requirements for
claims attachments?
_____ _____ _____ _____ _____


As one of the alternatives specified in the HIPAA Claims Attachments
Notice of Proposed Rule Making (NPRM), kindly submit your opinion to
www.cms.hhs.gov/regulations/ecomments . Click "Go" for CMS-0050-P,
fill in some minimal demographics on a screen, and then click
"Continue" to type up to 4,000 characters into the displayed comment
box ... and/or include a file as an attachment. If it's easiest, you
can just copy and paste the questions above into the comment box, and
then add your response following each. Or do the same in a file,
particularly if you have time to matrix your answers, and then attach
the file to the comment box.

[Note: Due to currently ongoing maintenance activities on CMS' web
site, the above url may not take you directly to the comment inputs
screens. Should that be the situation, as described in the NPRM,
telephone Lorraine Tunis Doo at 410-786-6597 for further instructions.]

Please comment no later than 5:00 p.m. Eastern time on Monday, 23
January 2006. Thanks in advance for your participation, and feel free
to forward this message to anybody else you believe would be interested
in opining.

Dave Feinberg
Rensis Corporation [A Consulting Company]
206-617-1717
DAFeinberg@...