Two points to keep in mind over the next ten days or so... .
~ Technical comments on the HIPAA Transactions NPRM proposed
version 005010 TR3 contents are generally planned to be
forwarded by CMS/OESS to X12 to obtain resolution
recommendations.
~ X12 will be holding its next Trimester Meeting the week of
21 September in Pittsburgh.
[See http://www.x12.org/x12org/meetings/x12trimt/index.cfm .]

As a consequence of this confluence, I suspect any comments on the
TR3's referenced in the recently published NPRM which can be submitted
at least a week prior to X12's Trimester Meeting would be welcome, would
likely receive highly focused attention, and could potentially provide
an early indication of any significant issues being discovered.

Note that submitting Transactions NPRM TR3 comments early does not in
any way preclude submission of further comments -- technical and
policy -- through the end of the NPRM public comment period on
10/21/2008.

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