October 15 is deadline for filing one-year HIPAA Transactions extension

   The deadline for filing the form that provides a one-year extension of time to comply with the HIPAA Transactions and Code Sets standards is just one week away - October 15, 2002.

    The Administrative Simplification Compliance Act (ASCA) enacted last December provides an additional year (until October 16, 2003) for covered entities (physicians, hospitals, and other health care providers that perform transactions electronically, as well as health plans, and clearinghouses) to come into compliance with the Transaction and Code Set standards. ASCA requires those entities needing additional time to come into compliance to file a form provided by the Centers for Medicare and Medicaid Services. (CMS). The CMS is itself filing for the extension. The Extension Form/Model Compliance Plan form can be accessed by going to the CMS HIPAA Web site at http://cms.hhs.gov/hipaa/. The form can be filed on-line on the CMS Web site, or by paper via facsimile or regular mail. To reiterate, the extension form must be submitted no later than October 15, 2002.    The only exemptions are if a physician practice does not submit electronic transactions and it does not accept Medicare patients OR a physician practice accepts Medicare but has less than 10 full-time employees and does not submit electronic transactions.  THERE IS A CATCH TO THESE EXEMPTIONS - On October 16, 2003 - there will be a mandate that physician practices MUST submit Medicare claims electronically - therefore, these exemptions are applicable for only one year - so it is in the best of interest of every physician to file for the extension before October 15, 2002.

   It should also be clear to physicians that the extension applies only to the Transaction and Code Set standards - not other HIPAA standards, such as the Privacy Rule. The deadline for compliance with the Privacy Rule remains April 14, 2003.

   Covered entities that are not compliant with the Transactions and Code Sets standards by October 16, 2002 and have not filed for the year's extension can potentially face exclusion from the Medicare program in addition to the penalties established in HIPAA for noncompliance.   Last week, all AMC/NOMA members received a packet of information regarding HIPAA rules.  If you have any questions, please contact the AMC/NOMA at (216) 520-1000, ext. 314 or email Louise Yardley with your questions at lyardley@amcnoma.org.