Technical Writing: Customer Bulletin

 

Customer Bulletin: CMS Defers Enforcing New HIPAA Transaction Standards

Date: February 27, 2012

Overview

  • The compliance date for covered entities to implement the new Health Insurance Portability and Accountability Act of 1996 (HIPAA) transaction standards remains January 1, 2012.
  • CMS will defer enforcement action for non-compliance with the new HIPAA transaction standards until March 31, 2012.
  • (Company A) has coded its year-end projects to comply only with the new HIPAA D.0 transaction standards that are based on CMS guidance issued prior to November 17, 2011.
  • To continue processing the existing HIPAA 5.1 transaction standards, customers must return a signed Customer Waiver of D.0 Exclusivity form to their business relationship manager (at A) by December 23, 2011.

What You Need To Know

On November 17, 2011, the CMS Office of E-Health Standards and Services (OESS) announced that CMS expects all HIPAA covered entities to begin using the new HIPAA D.0 transaction standards effective January 1, 2012. CMS will not take action against non-compliant covered entities until April 1, 2012.

On December 9, 2011, CMS distributed a memorandum confirming that while the compliance date for HIPAA II transactions remains January 1, 2012, they will defer enforcement actions against HIPAA covered entities not complying with the new HIPAA transaction standards within the first 90 days of the implementation date, including the following actions:

  • Using the new values (50, 60, 70, 80) in the Benefit Stage Qualifier field to allow the pharmacy to submit and process (in limited circumstances) both non-Part D drugs and Part D drugs not covered by the plan under a Part D bank identification number (BIN) or BIN and processor control number (BIN/PCN) combination
  • Processing Part D multi-ingredient compound (MIC) claims using the new HIPAA transaction standards, which requires the compound segment

Based on CMS guidance prior to November 17, 2011, (company name) coded its year-end projects to comply only with the new HIPAA D.0 transaction standards. Although CMS will defer enforcement action, customers who elect to continue processing with the existing 5.1 standards after January 1, 2012 will not be fully compliant with CMS.

To continue processing the existing HIPAA transaction standards (5.1), customers must return a signed Customer Waiver of D.0 Exclusivity form to their Company A business relationship manager by December 23, 2011. If Company A does not receive a signed Customer Request for Waiver of D.0 Exclusivity form by December 23, 2011, Company A will reject all 5.1 transactions received on and after 12:00 a.m. CST on January 1, 2012.

On September 16, 2011, CMS published a memorandum announcing that Part D customers have until April 1, 2012 to begin rejecting claims for 4Rx mismatches. CMS stressed that plan sponsors must assign a unique member identification number (RxID) as well as a unique Rx BIN or BIN/PCN combination for each Medicare Part D beneficiary. Part D customers must also update CMS systems with the beneficiary’s 4Rx data prior to January 1, 2012. CMS is not deferring enforcement action of this requirement and may issue notices to non-compliant covered entities effective January 1, 2012.

Action Required

  • Return a signed Customer Waiver of D.0 Exclusivity form to your business relationship manager at Company A by December 23, 2011 to continue processing the existing HIPAA transaction standards (5.1).
  • Please contact your account manager with questions.
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