Today, Friday 11/21/2008, is sixty days prior to 1/20/2009: the start
of the new Obama "Administration". Prior to most Federal Final Rules
taking effect, Congress gives itself a sixty day Review Period to
determine whether or not they wish to disapprove any Final Rule. {5 USC
Chapter 8} This sixty day period typically commences with the
publication of a Final Rule in the Federal Register; although, there are
some 'wrinkles' that extend the Review Period end date at the
adjournment of Congressional sessions -- such as will be occurring
shortly.

As of today, the publication of an Updated HIPAA Transactions Final Rule
hasn't happened. Thus, barring something weird, any new Updated HIPAA
Transactions Final Rule would become effective -- i.e., modified and new
transactions adopted -- during the Obama Administration; no earlier than
mid-March 2009, even if a Final Rule is published this year. Ditto for
any Final Rule for the ICD-10-CM and ICD-10-PCS code sets.

Note that March, 2009, effective dates do support compliance dates
contained in the Notices of Proposed Rule Making published on 8/22/2008.

Happy Thanksgiving, all.

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

P.S. A little bit of background on the 'why' of this message can be
found at http://www.ombwatch.org/regs/PDFs/BoltenMemo050908.pdf .

DAF