It appears that Accredited Standards Committee X12 is applying a very strict "catastrophic impediment to ... implementation" hurdle to forwarded Notice of Proposed Rule Making (NPRM) technical comments requesting changes to their version 005010 Type 3 Technical Reports (TR3's) proposed for HIPAA adoption on 8/22/2008. [See www.regulations.gov comment ID # CMS-2008-0101-0012.1 at
Should requested changes to the version 005010 TR3's not be incorporated, two other mechanisms are available for requesting these and additional changes to subsequent TR3 versions.
- Submit a change request to X12 via the Designated Standards Maintenance Organizations (DSMO) change request web site at http://www.hipaa-dsmo.org/Main.asp
- Attend future X12 Trimester Meetings listed at www.x12.org/x12org/meetings/x12trimt/index.cfm
If you plan to use the DSMO web site, do not delay any submissions. There is an approximately 3-6 month flow time for change request approvals prior to most TR3 writing work being initiated, and several X12 workgroups are already preparing the next presently planned versions of TR3's: 005050.
For attendance at X12 Trimester Meetings, it would be beneficial to send advance copies of any changes you'd like discussed to the co-chairs of the applicable workgroups for placement on workgroup session agendas. Co-chair e-mail addresses are located at
www.x12.org -->
Committees/Groups -->
Subcommittees -->
X12N-Insurance -->
TG2-Health Care,
and agendas are typically established about a month prior to each Trimester Meeting.
Bottom line, for now at least, assume any NPRM comment-requested version 005010 TR3 changes will not be incorporated, and start the request process for these changes in version 005050 as soon as feasible to ensure they are efficaciously carried forward.
Feel free to write back to me if you have any questions about the DSMO and X12 processes involved and/or their timings.
Dave Feinberg
Rensis Corporation [A Consulting Company]
206-617-1717
Author of "Understanding HIPAA Communications"