Practices should continue HIPAA Version 5010 implementation efforts

Despite the contingency plan issued by the Centers for Medicare & Medicaid Services in late December, physician practices still risk claims payment disruption if they do not completely convert to HIPAA Version 5010. Practices and others were required to transition to the latest version of the HIPAA electronic transaction standards by Jan. 1. Due to the lack of testing between providers and Medicare Administrative Contractors (MACs) on Version 5010 electronic transactions, CMS announced a contingency plan that included:

• Practices and clearinghouses that have tested with their MAC and have been approved for Version 5010 will be notified that they have 30 days to cutover to Version 5010.


• Practices and clearinghouses that have not yet tested were to be notified in December 2011 that they must submit their transition plan (including compliance timeline) to their MAC within 30 days of the notification. Those who submit a transition plan by the deadline will have until April 1, 2012 to complete their transition to the 5010 formats.


• Covered entities are afforded a 90-day enforcement delay at the discretion of the agency.

Practices should:

• Work with their trading partners (practice management system vendors, clearinghouses and health plans) to ensure that you are able to generate Version 5010 transactions as quickly as possible.


• Check with their clearinghouses to determine if they will be submitting the required “transition plan” (Notification will come from the MACs, with clearinghouses having the responsibility to notify the providers they service.


• Review the notification letter sent by the MAC to the practice that submit claims directly to a MAC and submit the required transition plan (Note: While there is no specific format required for the transition plan, submitters should outline the steps they have taken and the steps they still need to take to successfully achieve compliance with the updated version of the transactions.)


• Determine if their commercial health plans will continue accepting Version 4010 transactions and if so, for how long (If they will not, identify a clearinghouse or other contingency plan to ensure there is no disruption in cash flow.)
  Remember that despite CMS’ discretionary enforcement delay, the compliance date for these new standards remains Jan. 1, 2012.

For more information visit the CMS Web site.