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September 2012 HHS Releases Final Rule Addressing Compliance Date Change for the International Classification of Diseases, 10th Revision (ICD-10), Unique Health Plan Identifier (HPID), Other Entity Identifier (OEID) and National Provider Identifier (NPI)

On August 24, 2012, the Department of Health and Human Services (HHS) announced the release of the Final Rule that delays the International Classification of Diseases, 10th Revision (ICD-10) compliance date by one year. The new compliance date for ICD-10 is October 1, 2014. The rule entitled, “Administrative Simplification: Adoption of a Standard for a Unique Health Plan Identifier; Addition to the National Provider Identifier Requirements; and a Change to the Compliance Date for the International Classification of Diseases, 10th Edition (ICD-10-CM and ICD-10-PCS) Medical Data Code Sets” was published in the Federal Register on September 5, 2012.

Although the delayed compliance date alleviates some of the pressure on the ICD-10 implementation timeline, it is not an invitation to slow implementation activities in the Military Health System (MHS). The MHS will use the additional year to allow systems to undergo more thorough testing of ICD-10 updates before deployment.

In addition to the ICD-10 compliance date change, the rule adopts a standard for a Unique Health Plan Identifier (HPID) as well as an Other Entity Identifier (OEID) for entities that are not health plans, health care providers, or individuals that need to be identified in a Health Insurance Portability and Accountability Act (HIPAA) standard transactions. The compliance date for large health plans like TRICARE to obtain an HPID is November 5, 2014. The compliance date for using the HPID in HIPAA standard transactions is November 7, 2016, though there may be options to use the HPID before that date.

The rule also specifies circumstances under which an organization covered health care provider must require certain non-covered individual health care providers who are prescribers to obtain and disclose a National Provider Identifier (NPI). The compliance date for this provision is May 6, 2013.

The provisions of this Final Rule are expected to affect multiple administrative health care processes in the MHS; therefore, the Information Management-Business Division of TRICARE Management Activity has already begun to evaluate the impacts and formulate implementation plans.

To view the Final Rule, please click here.

August 2012 HHS Announced the Adoption of Operating Rules for Health Care Electronic Funds Transfer (EFT) and Electronic Remittance Advice (ERA) Transactions

On August 10, 2012, the Department of Health and Human Services (HHS) published an interim final rule with comment period (IFC) that adopts Operating Rules for health care Electronic Funds Transfer (EFT) and Electronic Remittance Advice (ERA) transactions. The IFC has a 60 day comment period, with comments due to HHS by October 9, 2012.

Earlier this year, HHS published an IFC adopting transaction standards for health care claim payments made via EFT and ERA. The purpose of the Operating Rules is to support and enhance the EFT/ERA standards and improve the transactions’ functionality by applying necessary business rules and guidelines. The compliance date for the EFT/RA standards and Operating Rules is January 1, 2014.

The new EFT/ERA standards and Operating Rules impact the electronic payment transmission mechanisms for TRICARE purchased care as a health plan and bill payer. There may also be future implications for the Services’ Third Party Collection (TPC) Systems if the Services elect to receive EFT/RA transactions as part of their Military Treatment Facility TPC billing processes.

To view the IFC, please click here.

July 2012 CMS Announcement: HIPAA Interim Final Rule with Comment Adopting Standards for Electronic Funds Transfers (EFT) and Remittance Advice (RA) is a Final Rule that is in Effect Now

In January 2012, the Department of Health and Human Services (HHS) published an interim final rule with comment period (IFC), (CMS-0024-IFC) adopting standards for the health care Electronic Funds Transfers (EFT) and Remittance Advice (RA) transaction under the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

On July 10, 2012, CMS announced that after reviewing comments received during the public comment period; the IFC, CMS-0024-IFC, as it was written, is a Final Rule and in effect now. This means industry implementation efforts should be underway toward the January 1, 2014 compliance date.

Covered entities must comply with the provisions of CMS-0024-IFC by January 1, 2014. However, there are no prohibitions against using the health care EFT standards before that date.

TRICARE as a health plan and payer entity will be required to implement the EFT/RA standards. Any Military Treatment Facilities that wish to receive EFT/RA would also need to do so using the newly adopted standards.

For more information, please view the EFT Fact Sheet and visit the frequently asked questions (FAQs) section of the CMS website.

April 2012 HHS Publishes Proposed Rule Addressing Unique Health Plan Identifier (HPID), National Provider Identifier (NPI) and Compliance Date Change for International Classification of Diseases, 10th Revision (ICD-10)

On April 17, 2012, the Department of Health and Human Services (HHS) published a Notice of Proposed Rule Making (NPRM) entitled, “Administrative Simplification: Adoption of a Standard for a Unique Health Plan Identifier; Addition to the National Provider Identifier Requirements; and a Change to the Compliance Date for ICD-10-CM and ICD-10-PCS Medical Data Code Sets.”

  • This NPRM first proposes the adoption of the standard for a national unique health plan identifier (HPID).
  • Secondly, it proposes adoption of a data element that will serve as an other entity identifier (OEID) for entities that are not health plans, health care providers, or "individuals" that need to be identified in Health Insurance Portability and Accountability Act (HIPAA) standard transactions.
  • Third, it proposes circumstances under which an organization covered health care provider must require certain non-covered individual health care providers who are prescribers to obtain and disclose an National Provider Identifier (NPI).
  • Finally, this rule proposes to change the compliance date for International Classification of Diseases, 10th Revision (ICD-10) from October 1, 2013 to October 1, 2014.
Military Health System (MHS) stakeholders are reviewing the NPRM, evaluating its impacts and will submit comments regarding all of its provisions to HHS. In the meantime and until a Final Rule is published, the MHS is staying the course and is continuing to work on transitioning to ICD-10 on the October 1, 2013 compliance date. Please click here for the NPRM published by HHS.

March 2012 CMS Extends Discretionary Enforcement Period for HIPAA Version 5010/D.0 Compliance

On March 15, 2012, the Centers for Medicare & Medicaid Services' (CMS) Office of E-Health Standards and Services (OESS) announced that it will extend the discretionary enforcement period for compliance with HIPAA X12 Version 5010, National Council for Prescription Drug Programs (NCPDP) D.0 and NCPDP 3.0 transactions for an additional three (3) months -- through June 30, 2012. For more information about the CMS compliance enforcement grace period, please click here.

February 2012 CMS Re-evaluates the Implementation Timeline for ICD-10

The Department of Health and Human Services (HHS) recently issued a press release to notify the health care industry that the Centers for Medicare and Medicaid Services (CMS) will re-evaluate the implementation timeline for the International Classification of Diseases, 10th Revision (ICD-10). Pending a final and official decision by CMS, the Military Health System (MHS) is staying the course and is continuing to work on transitioning to ICD-10.

February 2012 X12 Version 6020 Type 3 Technical Reports (TR3s)

The Accredited Standards Committee X12 (ASC X12) released the draft Version 6020 Type 3 Technical Reports (TR3) in November 2011 for public review and comment with a deadline for submitting comments by March 7, 2012. Version 6020 includes revisions that address many business needs and requests submitted by the health care industry, such as the Military Health System’s request to include a Military Dental Readiness Classification Code in the Reference Information (REF) Segment of the Health Care Claim Dental Technical Report (837D) for the Active Duty Dental Plan. Though Version 6020 had been anticipated to be the next adopted HIPAA transactions version after HIPAA X12 Version 5010 which was just implemented on January 1, 2012, based on industry feedback and the belief that the industry is not ready to begin another implementation cycle, X12 just recently announced that they will not recommend its 6020 TR3s to the Designated Standards Maintenance Organizations (DSMOs) for adoption under Health Insurance Portability and Accountability Act (HIPAA). Although the 6020 version will not be recommended for adoption, ASC X12 is still encouraging industry stakeholders to review the 6020 TR3s and provide comments because they will serve as a foundation for the next X12 version to be recommended for adoption.

To view the draft 6020 version, please follow the instructions provided by ASC X12 to download for no charge.

February 2012 CMS Discretionary Enforcement Period for HIPAA Version 5010/D.0 Compliance

In November of 2011, the Centers for Medicare and Medicaid Services (CMS) Office of E-Health Standards and Services (OESS) announced that it would not initiate enforcement action until March 31, 2012 with respect to any Health Insurance Portability and Accountability Act (HIPAA) covered entities that did not meet the January 1, 2012 compliance for use of X12 Version 5010 and the National Council for Prescription Drug Programs (NCPDP) Version D.0 HIPAA transactions. The compliance date for use of these new standards remains January 1, 2012 even though the enforcement grace period is in place.

While enforcement action will not be taken, OESS will continue to accept complaints associated with compliance during the 90-day period beginning January 1, 2012. If requested by OESS, covered entities that are the subject of complaints (known as “filed-against entities”) must produce evidence of either compliance or a good faith effort to become compliant with the new HIPAA standards during the 90-day period.

Payers may lawfully refuse to accept HIPAA X12 Version 4010/NCPDP Version 5.1.during the discretionary enforcement period; however, TRICARE will continue to accept and process HIPAA X12 Version 4010/NCPDP Version 5.1 claims in order to avoid payment disruption for providers who are still working to be HIPAA X12 Version 5010/NCPDP D.0 compliant.

All covered entities are encouraged by CMS to continue working with their trading partners to become compliant with the new HIPAA standards. For more information about the CMS compliance enforcement grace period, please click here.

February 2012 Interim Final Rule with comment Period (IFC) for Adoption of Electronic Funds Transfer (EFT) & Remittance Advice (RA)

On January 10, 2012, the Department of Health and Human Services (HHS) published an Interim Final Rule with Comment Period (IFC) entitled: Administrative Simplification: Adoption of Standards for Health Care Electronic Funds Transfers (EFTs) and Remittance Advice (RA).

The Rule adopts streamlined standards for the format and data content of these transactions. Currently when a provider submits a claim electronically for payment, a health plan often sends an RA separately from the EFT payment. The disconnect between the two makes it difficult or sometimes impossible for the provider to match up the RA and the corresponding payment. The rule addresses this by requiring the use of a trace number that automatically matches the two. This new tracking system will allow health care providers to eliminate costly manual reconciliation that must currently be done.

The regulation is effective January 10, 2012. All HIPAA covered entities engaging in EFT/RA transactions must comply by January 1, 2014.

To view the IFC, please click here.

* For TRICARE HIPAA Privacy and Security pages, please click here.

“On October 1, 2013, the Department of Defense established the Defense Health Agency (DHA) to manage the activities of the Military Health System. These activities include those previously managed by TRICARE Management Activity (TMA), which was disestablished on the same date. During the next several months, all TMA websites will change to reflect the new DHA. We appreciate your patience during this transition."
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