Anesthesia Coding Alert

Question: We're behind schedule with our HIPAA 5010 implementation and are not sure that we'll be ready for it on January 1. What can we do to get on track?

Minnesota Subscriber

Answer: Even though you might be behind schedule in the testing phases, start now before it does become too late. Focus on testing things with your clearing house until all error messages are gone. Other tips from experts include:

• Check whether your clearinghouse has already tested claims with other users of your software. If so, the software might have an update available to accommodate the required changes.
• Contact your largest payers to see if they have any issues you should know about or if they have any contingency plans and what those might be.
• Consider submitting as many transactions as possible before Dec. 31, 2011 using your current system.
• If you experience problems with testing or getting claims paid after the Jan. 1 deadline, drop your claims to paper until the problem is resolved.

Relief: Although a "grace period" hasn't been established, a Nov. 17, 2011 statement from CMS announced a 90-day "period of enforcement discretion for compliance" with HIPAA 5010. The announcement states that CMS "would not initiate enforcement action until March 31, 2012, with respect to any HIPAA covered entity that is not in compliance with the ASC X12 Version 5010 (Version 5010), NCPDP Telecom D.0 (NCPDP D.0) and NCPDP Medicaid Subrogation 3.0 (NCPDP 3.0) standards. Notwithstanding OESS' discretionary application of its enforcement authority, the compliance date for use of these new standards remains January 1, 2012"

For more information on HIPAA 5010, visit www.CMS.gov/Versions5010andD0