HIPAA’S ELECTRONIC
DISCLOSURE REQUIREMENTS
October 16, 2002 - ARE YOU READY?
The electronic disclosure requirements under the Health Insurance
Portability and Accountability Act ("HIPAA") will become
effective for most covered entities on October 16, 2002. Health
plans with more than $5 million in premium payments, health care
providers and health care clearinghouses must have the capacity
to electronically process eight types of transactions using the
code set designated by federal regulation. Small health plans (those
with $5 million or less in annual premium payments) have an additional
year -- until October 16, 2003 -- to comply.
The following transactions are subject to the electronic disclosure
rules:
-
Requests to obtain payment, and the necessary
accompanying information from a health care provider to a
health plan for health care.
-
An inquiry from a health care provider to
a health plan, or from one health plan to another health plan,
to obtain eligibility information.
-
A request for authorization for health care
including a request to refer an individual to another health
care provider.
-
An inquiry to determine the status of a health
care claim.
-
The transmission of participant information
for enrollment or to terminate coverage.
-
The transmission from a health plan to the
health care provider’s financial institution of a payment,
information about the transfer of funds or payment processing
information, as well as the transmission from a health plan
to a health care provider of explanation of benefits.
-
The transmission from the entity arranging
health coverage (employer) to the health plan of a payment,
information about the transfer of funds, as well as transmission
of payment processing information, including payroll deductions
and detailed remittance information about individuals for
whom payment is being made.
-
The transmission from an entity to a health
plan to determine the relative responsibility of the health
plan for claims and payment information.
Even the entities subject to the 2002 deadline
can obtain a one-year extension of the deadline for meeting these
rules by filing a Compliance Statement with the Department of
Human Services no later than October 15, 2002. This extension
can be filed electronically at: www.cms.hhs.gov/hipaa/hipaa2/ascaform.asp.
As most employers know, the HIPAA privacy rules take effect April
14, 2003, for health plans with more than $5 million in annual
premium payments as well as for health care providers and health
care clearinghouses. By this date these covered entities must
have appointed a privacy officer, trained employees who have access
to personal health information about the privacy rules, designed
and implemented policies and procedures designed to safeguard
personal health information, amended plan documents, and prepared
and distributed notices to plan participants advising them of
their privacy rights.
If we can assist your company in complying with these rules or
requesting an extension of the effective date, please contact
Ira Friedrich (404-230-6714) or Carl Cannon (404-230-6717) in
Constangy’s Atlanta, Georgia, office or Dana Thrasher (205-252-9321)
in Constangy’s Birmingham, Alabama, office.
