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The Privacy Symposium The Sixteenth National HIPAA Summit Cambridge, MA. Transactions, Code Sets and Identifiers (NPI) Update. Jim Whicker , CPAM Intermountain Healthcare Director of EDI, A/R Management Chair, WEDI AAHAM EDI Liaison. NPI – Our Experiences. Claims processing ok
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The Privacy Symposium The Sixteenth National HIPAA Summit Cambridge, MA Transactions, Code Sets and Identifiers (NPI) Update Jim Whicker, CPAM Intermountain Healthcare Director of EDI, A/R Management Chair, WEDI AAHAM EDI Liaison
NPI – Our Experiences • Claims processing ok • Concern for some providers as not all segments fully NPI only • Unexpected rejections • Payer Crosswalks • Inability to handle provider who practices in multiple locations • 835’s processing mostly without incident • Some payers have difficulty with paper and crossover claims • Clearinghouse/Payer creating loops and segments not on outbound claim then rejecting claim for non compliance!
National Provider ID - NPI • Additional Issues: • Provider required to submit NPI on bill even when referring doc has no NPI/Unable to obtain • Medicare Transmittal 235 made recommendations, but has since been rescinded without alternative • Provider NPPES and IRS name mismatch • Requirement to Update 855 documents with CMS and wait to update NPPES until AFTER CMS updates internal systems. • Interaction issue between NPPES and PECOS • CMS has processing issues for certain institutional bill types hitting the right area internally for payment.
"You really don't need my driver's license officer...I have an NPI, a 10-digit, intelligence-free, numeric identifier." Cartoon by Dave Harbaugh
NPRM – 5010, D.0, and ICD-10 • Information released for public view Friday, August 15 • Publication in Federal Register August 22, 2008 • Comments Due October 21, 2008 • For 5010 and D.0 • Industry internal review for changes – begin September 2008 • Internal/External Testing by April 2009 • CMS expects to have full compliance by April, 2010 • Short process for review of comments and posting of final rule? • For ICD-10 • Industry begin design and documentation June 2009 • Industry build and internally test system changes December 2009 • Test with trading partners July 2010 – October 2011 • Full compliance October 2011 • Still no Attachments final rule, nor plans for a National Payer ID • Recommendation to adopt Acknowledgements, Standard ID Card
5010? Why? • Current transactions are over 6 years old • More than 500 industry requested changes via DSMO • Many more industry requested changes via ASC X12 • Addresses problems encountered with 4010A1 • Improvements to implementation instructions • More consistent implementations by trading partners • Should reduce Companion Guide TP requirements
Upgrade not a HIPAA “Do-over” • Change analysis will require a thorough review of all transaction TR3s • Analysis is X12 to X12 • Less complicated than with round 1 • Changes are not a 100% change • Some transactions changed very little • Other transactions changed moderately • Others had significant changes (claims)
General changes to all transactions • More standardized front matter • Addressed industry needs missing from 4010 • Clarified intent where previously ambiguous • Clarified, Added, or Deleted code values and qualifiers: • To address industry requests • To reduce confusion from similar or redundant values • TR#’s (Implementation Guides) “Free” for 4010, Must be purchased for 5010
837 – Health Care Claims (I, P, D) • Fixed significant industry problems: • Improved front matter explanation of COB reporting and balancing logic • Added COB crosswalk – and examples • Section added to explain allowed and approved amounts • Subscriber/patient hierarchy modified • 837I Provider types were redefined in conjunction with the NUBC code set
837 – Health Care Claims (cont’d) • Improved rules and instructions for reporting provider roles and use of NPI • Added front matter sections to: • Explain Medicaid subrogation • Pay-to Plan information • Explain reporting of drug claims • POA Moved to a specific segment rather than “Kludged” • Capability to do ICD-10 • 837 Professional - Anesthesia minutes • Ambulance “Pick-up” information added • Dental – easier to coordinate benefits between dental and medical plans • Start/Stop dates for crowns/bridges • Allows for Tooth numbers with International systems
835 – Claims Payment/Remittance • Many improvements are in the Front Matter • Tighter business rules to eliminate options and codes • Allows compatibility with claims sent under version 4010 for transition • Added Health Care Medical Policy – via payer URL • Claim status has clearer guidance to report how a claim was adjudicated • Better instructions for handling reversals and corrections; interest payments and prompt pay discounts • Limits use of denial claim status to specific business case • Advanced payments and reconciliation • Secondary payment reporting considerations section revised
834 - Enrollment/Disenrollment 820 – Premium Payments • 834: • Allow usage of ICD-10 for reporting pre-existing condittions • Privacy issues addressed • Added codes to explain coverage changes • Clarifies usage of coverage dates • 820: • Ability to report additional deductions from payments • Method used to deliver remittance • Simplifies and clarifies when adjustments to previous payments are needed
270/271 – Eligibility • Clarified instructions for sending inquiries: • When subscriber is patient • When dependent is patient • Newly required response information • When a patient has active benefit coverage, the health plan must report: • Beginning effective eligibility date, Plan name, and the Benefit effective dates if different from the overall coverage. • All demographic information needed by the health plan on subsequent transactions must be reported, primary care provider if available, and other payers if known.
270/271 – Eligibility • Required alternate search options • When payers are unable to find member eligibility information using all the data elements of the primary search, health plans must support inquiries with: • Member ID, Last name only, and Date of Birth to help eliminate false negatives. • This was a controversial requirement, and was just modified during the June trimester meeting, changes to the TR3 (Implementation Guide) will be forthcoming to reflect this modification.
270/271 – Eligibility (cont’d) • Nine categories that must be reported • Medical Care • Chiropractic Care • Dental Care • Hospital • Emergency Services • Pharmacy • Professional Visit – Office • Vision • Mental Health • Urgent Care
270/271 – Eligibility (cont’d) • Clear requirements for reporting patient responsibility with a monetary amount or percentage • Added 38 new service type codes
276/277 – Health Care Claim Status • Eliminated sensitive patient information that was unnecessary for business purpose • Added Pharmacy related data segments and the use of NCPDP Payment Reject Codes • Increased Claim Status segment repeat to > 1 for more detailed status information • Added more examples to clarify instructions
278 – Referral Certification and Authorization • Little implementation due to constraints under 4010 • Added segments for reporting key patient conditions • Added/expanded support for various business needs • Expanded usage for authorizations