Responding to the July 8 interim final rule to adopt operating rules for electronic insurance eligibility and claims status transactions, the American Hospital Association is urging federal officials to also adopt the operating rule for acknowledgements.
All three rules are parts of Phases I and II of the Committee on Operating Rules for Information Exchange initiative of CAQH, an alliance of industry stakeholders. The Affordable Care Act mandates adoption of a series of operating rules between 2013 and 2016.
Thus far, the Department of Health and Human Services has adopted the eligibility and claim status rule. But the AHA says the acknowledgements rule is critical for maximizing the benefits of other operating rules. "Both providers and health plans view acknowledgements as essential to improving the end-to-end processing of transactions because they let both parties know that electronic transactions from the other have been received and accepted, thereby avoiding the electronic 'black hole' into which transactions can fall," AHA contends in a comment letter to the Centers for Medicare and Medicaid Services. "Delaying inclusion of the acknowledgement rule leaves ambiguity in the data exchange process and severely undermines adoption of the operating rules."
HHS has not adopted the acknowledgement transaction as a HIPAA standard, but the AHA notes that Congress did not limit the scope of operating rules to address only HIPAA-mandated standards. The reform law, in fact, permits development of operating rules that meet common business needs that HIPAA does not address, including those that "provide for timely acknowledgement," the association adds.
Delaying mandatory use of acknowledgements until HHS adopts them as a HIPAA standard "will have a negative effect on the goals of administrative simplification for the first several years of implementation," according to the AHA comment letter. Other AHA recommendations include:
* HHS should name CAQH CORE as the single operating rule authoring entity for all medical transactions, and
* Issue the final rule for the first operating rules before January 2012 if at all possible.
Under the Affordable Care Act, CMS must adopt rules for eligibility and claims status transactions by July 1, 2011, effective Jan. 1, 2013. Rules for electronic funds transfer and payment/remittance advice transactions must be adopted by July 1, 2012, effective Jan. 1, 2014. CMS must adopt rules for claims/encounters, enrollment/disenrollment, health plan premium payments, and referral certification /authorization by July 1, 2014, effective Jan. 1, 2016.
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