The National Committee on Vital and Health Statistics (NCVHS) meetings
on 30-31 July 2007 focused almost completely on newer versions of
current HIPAA transactions; for retail pharmacy as well as those from
X12. Approval of these newer versions by the NCVHS is a required,
major, milestone in the process for adopting these newer transactions
for HIPAA and replacing those currently in use. An extract of the
results from these meetings follows.
_____ _____ _____ _____ _____ _____ _____

"Summary of Final Subcommittee Discussion

"Dr. Steindel suggested that the Subcommittee recommend to the Secretary
that they move forward with an NPRM for 5010. He indicated that the
regulatory process must begin in order to coalesce industry opinion.
Perceptions within the industry would change, he said, after an NPRM was
published and its feedback analyzed by CMS. Dr. Blair spoke of a "window
of opportunity" to educate the industry within the next six months to a
year. Dr. Warren, who indicated that all Subcommittee members agreed
with Dr. Steindel's recommendation, wondered about the timeline. Dr.
Cohn mentioned that CMS outreach was defined, for these purposes, as
bringing together stakeholders and implementers to talk about strategy.
He noted industry unanimity about a two-year implementation from
publication of the final rule, which might be best accomplished at a
different time than the ICD -10 implementation. Mr. Reynolds wanted to
ensure that the 5010 business case would be well-known by the industry.
As a matter of public record, Dr. Cohn stated that the Subcommittee
welcomes letters and comments from the public. Mr. Blair recommended
that the NPRM should: 1) alert the industry that a change is coming and
encourage the industry to "start moving"; 2) strengthen the business
case; and 3) clarify how testing should take place and determine who
will coordinate and perform it.

"ACTION STEPS

"1.. Dr. Warren, who will work with Mr. Reynolds and Ms. Buenning to
draft the Subcommittee's letter to the Secretary, requested input and
definitions from Subcommittee members (e.g., "staggered implementation";
"pilot testing"; "plan"; "testing"; "certification"; "dual processing";
"NHIN"). The letter will include the Subcommittee's recommendation that
the NPRM go out. The intent is to present a letter for consideration by
the full Committee at the September 2007 meeting.
"2.. A conference call will be scheduled to review the draft letter.
"3.. Dr. Cohn suggested a review of the Claims Attachment letter along
with the recommended testing (i.e., prior to promulgation of the final
rule).
"4.. Dr. Cohn recommended consideration of how gathering information
about testing, standards certification, and additional review could be
reflected in the next HIPAA certification. He requested guidance or
advice (possibly CMS might query the standards organizations as part of
an NPRM).
"5.. Dr. Cohn suggested that the Subcommittee assist CMS as it begins
to develop an NPRM. The Subcommittee can provide a different view of
return on investment and benefits. Ms. Trudel noted the importance of
conveying the appropriate information to HHS policymakers."
_____ _____ _____ _____ _____ _____ _____

The complete Meeting Summary and transcripts from both days of meetings
can be accessed via http://www.ncvhs.hhs.gov/070730ag.htm .

Dave Feinberg
Rensis Corporation [A Consulting Company]
206-617-1717
DAFeinberg@...
Author of "Understanding HIPAA Communications