CONTACT OHS WITH HIPAA QUESTIONS

[From a press release dated 8 November 2004]

The Accredited Standards Committee (ASC) X12 and the Data Interchange
Standards Association (DISA) are pleased to announce the launch of the
ASC X12 Implementation Guide Request for Interpretation Web site.

The site initially gives visitors "access to the experts" in the ASC X12
Insurance Subcommittee (ASC X12N) for those Implementation Guides (IG's)
that have been adopted for use under HIPAA. The site allows for
submission of detailed questions about interpretation of these IG's.
While it does not replace the need for standards implementers to read
the IG's and do their own analysis, it does provide a location to find
resolution of issues of interpretations or  inconsistencies within or
between the IG's.

The Web site serves as the interface to a database or repository of
questions and answers from expert volunteers within the Insurance
Subcommittee. As requests and responses are accumulated, the site allows
searching of the database and access to prior interpretations, making it
an invaluable resource for implementers.  A further benefit of this
database is to help support industry needs by identifying areas of the
IG's that should be improved in future versions.

The HIPAA Implementation Guides Interpretations Web site is initially
located at www.x12n.org/portal .


[The complete press release may be accessed at www.disa.org/pr01.cfm .]

                     Dave Feinberg
                     Co-chair, HIPAA Implementation Work Group
                          Insurance Subcommittee (X12N)
                          Accredited Standards Committee X12
                     Rensis Corporation  [A Consulting Company]
                     206-617-1717
                     DAFeinberg@...

P.S.    Requests for changes to HIPAA Implementation Guides should
continue to be submitted at www.hipaa-dsmo.org/crs .

                     DAF

Hello,

This email message is a notification to let you know that
a file has been uploaded to the Files area of the ShareHIPAA
group.

   File        : /NPIapp3_03tl.doc
   Uploaded by : sharehipaa <sharehipaa@...>
   Description : Msg #238 NPI Application DRAFT Oct 15 2004

You can access this file at the URL:
http://groups.yahoo.com/group/ShareHIPAA/files/NPIapp3_03tl.doc

To learn more about file sharing for your group, please visit:
http://help.yahoo.com/help/us/groups/files

Regards,

sharehipaa <sharehipaa@...>

For those who may be interested, attached is the draft version of the
National Provider Identifier Application being used for evaluation under
the Paperwork Reduction Act.  It was referenced on page 61257 of the
Federal Register dated 15 October 2004.

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

An addenda to X12N's version 003070 Implementation Guide noted in the
forwarded message is now available for public comment.  The underlying
Implementation Guide has not been adopted under HIPAA and no official
discussions regarding any such adoption of it or its addenda have been
held.  A factor in such discussions, should they be initiated, will be
any comments received.  Participation in the public comment period is
open to all who may be interested.  Please participate if you are able.

                     Dave Feinberg
                     Co-chair, HIPAA Implementation Work Group
                          Insurance Subcommittee (X12N)
                          Accredited Standards Committee X12
                     Rensis Corporation  [A Consulting Company]
                     206-617-1717
                     DAFeinberg@...


----- Original Message -----
From: Mike Cabral
Sent: Friday, October 22, 2004 8:10 AM
Subject: Announcing a Public Review Period of Addenda for 277 Health
Care Payer Unsolicited Claim Status Implementation Guide (003070X070A1)


Announcing a Public Review Period of Addenda for 277 Health Care Payer
Unsolicited Claim Status Implementation Guide (003070X070A1).

The ASC X12N Health Care Health Care Payer Unsolicited Claim Status
(277) Implementation Guide Addenda (003070X070A1) is now available for
industry review.  This Addenda document has been developed by X12N TG2
WG5, which is the Claim Status work group within the Health Care task
group of the Insurance Subcommittee of X12.  X12 is an Accredited
Standards Committee (ASC) under ANSI (American National Standards
Institute).

The purpose of the 277 implementation guide is to:
·        Provide claim status information from the payer without health
care provider solicitation

Examples of this type of claim status notification include
acknowledgements of claim transmission and pended claim lists from a
payer organization.

The Addenda for this guide is based on version 3070 of the ASC X12
family of standards.

The public review period will commence at 8:00 P.M. Eastern on October
25th, 2004 and will close at 8:00 P.M. Eastern on November 24th, 2004.

The authors will review and discuss any and all comments following the
public review period.  Official work group responses will be posted to
the on-line conference.  All work group responses will be posted at
least 15 days prior to the corresponding Information Forum. This is the
only public review period.  For a complete understanding of changes
being made to the guide, reviewers should monitor the on-line conference
during the public review period and review all author responses prior to
the Information Forum.

Watch for the announcement of the corresponding Information Forum. The
Information Forum is the final opportunity to comment on modifications
based on the public review period comments.

The draft implementation guides are available for download at:
http://www.wpc-edi.com/HealthCareDraft.asp

Comments on the draft implementation guides can be submitted via the
on-line conference at:
http://www.wpc-edi.com/conferences/healthcare.html


Michael J. Cabral, Project Manager
Claim Status Work Group Co-Chair

-----Original Message-----
From: Tom Austin [mailto:austin@...]
Sent: Thursday, October 21, 2004 8:09 AM
To: ShareHIPAA@yahoogroups.com
Subject: [ShareHIPAA] RISK ANALYSIS: For the Small Medical Practice, Just How Much Is Enough?

Looking at some compliance toolkits that healthcare attorneys are offering their clients, I continually get disappointed.

These toolkits offer risk analysis, and policies and procedures all in one package (typically from about $100 and up) but they just do not cover enough - especially in the technical area.  Moreover, depending on the toolkit, the policies and procedures may not be that good either.  The pitch is that the toolkit makes it easy for a small practice to become compliant. Has anyone come across a toolkit that they feel is reasonable and appropriate for small practices?  

As a consultant, I want to ensure that my clients understand and implement appropriate policies, procedures and tools based on an "accurate and thorough" risk analysis.  However, determining "what is enough analysis" to say that it is accurate and thorough for a small practice is a big question.  When I asked one attorney about whether his toolkit would satisfy due diligence in using his toolkit for small practices, he did not respond. 

I've raised this issue in an article in my newsletter and have also posted it on my website at http://www.ibg.com/ShadesOfGrayOpinion.html#RISK   In case you're interested in the newsletter, it's posted at http://www.ibg.com/newsletters/SecurityNewsletterIBGOct-Nov04.htm

Your thoughts and comments on risk analysis are welcome.

Regards,
Tom
http://www.ibg.com/people/tom_austin.html

ibg internet business group
201 Liberty Hill
Bedford, New Hampshire 03110
Phone 603.471.2700

"ibg. The knowledge to secure your business." ^®

 

September 29, 2004 - New California Information Security Privacy Law:

http://info.sen.ca.gov/pub/bill/asm/ab_1901-
1950/ab_1950_bill_20040929_chaptered.pdf

On September 29, 2004, Governor Schwarzenegger signed A.B. 1950, a
bill that imposes new information security duties on businesses that
keep personal information about California residents, including an
obligation to contractually bind non-affiliated parties to protect
shared information. The new law becomes effective January 1, 2005.


Chris Dirricq
Hoag Hospital
Newport Beach, CA.

Over the past years, many of you have asked for an implementation guide
that may be followed to acknowledge transactions at a more detailed
level than that allowed by a TA1, 999, or 997 transaction.  A draft
version of such a guide is now available for public review and comment
as a key step in its X12 Type 3 Technical Report (TR3) publication
process.  The public comment period commenced October 1, 2004, and
will close on November 30, 2004, at 5:00 pm Eastern time.

The purpose of the X12N Health Care Implementation Guide and Application
Reporting (824) Implementation Guide, 005010X186, is to:
· Enable a receiver of an X12 transaction, related to insurance business
   processes, to report errors that are outside of the scope of the 997
   or 999 error reporting, or to report the results of an application
   system's data content edits of transaction sets.
· Report transaction errors related to the use of any other approved
   implementation guide that does not have another standard vehicle for
   the reporting of such errors.
· Supplement other error-reporting vehicles that may not provide for
   reporting of every transaction set error.

Note that this 824 implementation guide does not replace existing
approved implementation guides designed to report transaction errors;
such as the 277 implementation guide designed for reporting certain
implementation-related errors and status in the 837.  Nor does it
replace transaction-specific 824 implementation guides such as the
266/824 or the 148/824.

The authors of this guide will consider all comments following the
public comment period. Official work group responses will be posted to
the on-line conference at least 15 days prior to the corresponding
Informational Forum. This is X12's only unconstrained public comment
period.  For a complete understanding of changes being suggested and/or
made to the guide, reviewers should monitor the on-line conference
during the public comment period and consider all author responses prior
to the Informational Forum.

An announcement of the corresponding Informational Forum will be made
later.  The Informational Forum, held during an X12 Trimester Meeting,
probably the one during the first full week of February, 2005, [see
http://x12.org/x12org/meetings/x12trimt/index.cfm ], is the final X12
opportunity to comment:  but only on modifications based on the received
public comments.  After that, the guide is finalized for movement
through the Insurance Subcommittee (X12N) and X12 publication approval
processes; and perhaps proposal as a new HIPAA standard.

The draft implementation guide is available for free download at:
http://www.wpc-edi.com/HealthCareDraft.asp . Comments on the draft can
be submitted by anybody via the on-line conference at:
http://www.wpc-edi.com/conferences/healthcare.html .

This Implementation Guide is not a counterpart of any that have been
adopted under HIPAA, and no official discussions regarding any such
adoption have been held.  A factor in such discussions, should they be
initiated, will be any comments received.  Voluntary use, once this
guide is published as a TR3, is, of course, permissible at any time
based on negotiated agreements between willing trading partners.  HIPAA
is a floor, not a ceiling!

Participation in the public comment period is open to all who may be
interested.  Please participate -- this is the highest leverage
opportunity for anybody outside of the authors to impact this document.
Also note that this is a version 005010 guide.  A version
004010 guide is also being written and is presently projected for public
comment during June-July, 2005 [see
www.x12.org/x12org/subcommittees/X12N/N0200_X12N005010_TR3.pdf ].

                     Dave Feinberg
                     Co-chair, HIPAA Implementation Work Group
                          Insurance Subcommittee (X12N)
                          Accredited Standards Committee X12
                     Rensis Corporation  [A Consulting Company]
                     206-617-1717
                     DAFeinberg@...

It was Memorial Day weekend when local resident Chris Aiken made the
discovery. Taking boxes of his own to one of the local drop off
points, he was dismayed to find that the bin was clogged. But it was
the bin's contents that disturbed him the most: unshredded
medical records on just under 30 patients treated by a Dr. Jennings
Pressly.

http://health-
information.advanceweb.com/common/Editorial/Editorial.aspx?CC=
41557


Chris Dirricq
Information Security
Hoag Hospital - Newport Beach, CA.

For those who may not have received this via other routes.

Additionally, you may be interested that no Enumerator contract has yet
been awarded.  Charlie's latest estimate for the RFP is "early October".

----- Original Message -----
From: "Charles Waldhauser" <CWaldhauser@...>
Sent: Friday, September 24, 2004 10:59 AM
Subject: Re: NPI Bulk File Load Information

I am attaching some basic high level information about how we are
envisioning the bulk file enumeration process (which we are calling
electronic file interchange) to work.  Comments and questions are
welcome.

Charlie Waldhauser

In addition to its usual standards creation activities, Accredited
Standards Committee X12 will be having presentations on adopting the
next generation of HIPAA transaction standards, and the National Health
Information Infrastructure and HL7's draft Electronic Health Record
Standard.  Short descriptions of each of these presentations are at the
end of this message.

Information on attending these sessions at X12's Miami [Hyatt Regency
hotel] Trimester meeting the first week in October can be found at
http://x12.org/x12org/meetings/x12trimt/index.cfm .  First time
non-members may attend X12 Trimester meetings for free.  At
this late date, contact Diane Huber, dhuber@... , if you're
interested in this option.

The sessions described below are an excellent opportunity learn more on
these two key topics at one time.  Take advantage of them, as well as
the entire X12 experience, if you can.

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

X12N/TG3/WG3 "HIPAA Implementation / Coordination"
             presents another installment of the
       HIPAA INFORMATIONAL FORUM

                   Wednesday Afternoon
                    6 October 2004
                    Ashe Auditorium


3:00-4:00     HIPAA Transactions - The Next TR3's
         A discussion of the materials, processes, schedules, and some of
         the as-yet unanswered questions involved in creating the next
         iteration of HIPAA standard transactions.

4:00-5:00     The NHII and HL7's Draft EHR-S Standard
         A report on HHS' National Health Information Infrastructure
         (NHII) Summit on Health Information Technology held this past
         July and Health Level Seven's (HL7) recently approved Electronic
         Health Record System (EHR-S) draft standard.  Included is an
         analysis of their potential relationships with HIPAA transaction
         standards.


Note:  "HIPAA and X12 -- An Introduction", a.k.a.
            HIPAA-101, is scheduled for presentation
            at 11:00 on Monday morning as part of the
            Newcomer Orientation in Gautier; see
            attachment.
______________________________________________________________

Hi everybody,

Following an X12 conference call yesterday, it appears that work on the
next generation of Implementation Guides -- now known as Type 3
Technical Reports (TR3's) -- remains on schedule.  Because of the long
lead times in the HIPAA transactions adoption process, the next months
are going to be critical.  X12 public comment periods -- see
attachment -- are the greatest leverage point for folks who don't
regularly participate in X12 to contribute their expertise to this next
generation of potential HIPAA standards.

An understanding of what's happening to create this next generation of
federally mandated healthcare EDI standards is also key for impacted
organizations' planning.  This is the reason I've created the
presentation "HIPAA Transactions -- The Next Generation" plus a full day
seminar "HIPAA TCS -- What's Next?  Products, Processes, and
Prognostications".

I'd be delighted to continue presenting either or both to any
organizations you know of that need to be aware of what's happening.
There's a window opening where anybody can participate in the HIPAA
standards creation process.  I don't think it should be missed simply
because people didn't know about or understand it.

Please feel free to contact me at any time should you have any questions
or desire any additional information.  Also, could you post and forward
the attachment to as many folks as possible to help get the word out?
Thanks.

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

The new HIPAA rule for Civil Money Penalties (CMP) that went to the
Office of Management and Budget on 9 August was published on pages
55515-55516 of today's Federal Register: Volume 69, No. 178, Wednesday,
15 September 2004.  It extends the expiration date of the CMP Interim
Final Rule originally published on 17 April 2003.  The new expiration
date is now 16 September 2005.

No other changes to the original CMP rule are included in today's
Federal Register rule.

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

http://www.nydailynews.com/news/local/story/230961p-198366c.html