A hospital's IT project list is most likely an exponential one: Convert to an EHR, transition to HIPAA 5010, coordinate vendor and health plan testing, train staff members on new technology, prove meaningful use, and qualify for incentive payments under the American Recovery and Reinvestment Act. It's enough to make anyone's head spin.
"Institutions are being forced to downsize and limit their scope in today's economy. Never has so much needed to be done with so few resources," says Dan Rode, MBA, CHPS, FHFMA, vice president of policy and government relations for the American Health Information Management Association in Washington, DC.
Deadline is January 2012
The transition to HIPAA 5010 is perhaps the most pressing issue because its compliance deadline is little more than two years away. Providers must be ready to submit claims electronically using the upgraded HIPAA standards by January 1, 2012—nearly one year prior to the October 1, 2013 ICD-10 deadline.
CMS recently held its first national provider education call about HIPAA Version 5010, during which it provided an overview of the updated national code standard for billing software and answered several questions from providers, vendors, and other health information management and health information technology professionals.
The X12 Version 5010 and the National Council for Prescription Drug Programs Version D.0 standards will incorporate more than 500 change requests, resolve ambiguities in situational rules, and provide more consistency across transactions, said Kyle Miller, health insurance specialist in the Office of E-Health Standards Services of CMS, during the call.
New data element requirements
In some cases, version 5010 will also include new data element requirements, said Chris Stahlecker, the director of the Division of Medicare Billing Procedures for CMS, during the call. "Everyone should realize that the software used today to produce the EDI transactions must be modified to exchange the new formats," she added. "In addition, you may discover that your business processes may need to be changed."
Medicare has performed a comparison of the current and new formats that hospitals can use to begin performing a gap analysis and evaluate the impact on routine operations.
Medicare Administrative Contractors must be ready to use 5010 by January 1, 2011, giving providers one full year to coordinate testing efforts, Stahlecker said.
The Medicare fee-for-service implementation of 5010 will include the following:
- Improved claims receipt, control, and balancing procedures
- Increased consistency of claims editing and error handling
- Improved efficiency for returning claims needing correction earlier in the process
- Improved assignment of claim numbers closer to the time of receipt
Increased field size
The Medicare implementation will result in an increased field size for ICD-10 codes from five bytes to seven bytes. It will also add a one-digit version indicator to the ICD code to indicate version nine versus 10. Finally, it increases the number of diagnosis codes allowed on a claim from eight to 12.
Each MAC will be required to undergo a certification process using self-developed criteria no later than November 31, 2010 to accommodate the 2011 compliance deadline.
"Although we have multiple MACs with individual systems, we want each one to perform as if it were a virtual single system," Stahlecker said. "No matter which MAC you are exchanging transactions with, you should experience very similar processing results."
In addition, CMS will post on each MAC Web site a list of vendors who have completed their testing for the 5010 format.
"Contact your system vendors right away," Stahlecker said. Ask specifically about whether your licensing agreement includes regulatory updates, she added. "If it does, you may have a shorter path toward your implementation, but if it does not, you may have a long procurement path to follow."
CMS said providers should also inquire whether any potential upgrades include acknowledgement transactions 277CA and 999 as well as a "readable" error report produced from those transactions.