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HIPAA and ACA Timeline Change Healthcare Quarterly Updates

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Q1 2016 Update Published: February 12, 2016 Q2 2016 Update Available: No later than May 13, 2016 HIPAA and ACA Timeline Change Healthcare Quarterly Updates 2.12.2016
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Page 1: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

Q1 2016 Update Published: February 12, 2016

Q2 2016 Update Available: No later than May 13, 2016

HIPAA and ACA Timeline

Change Healthcare Quarterly Updates

2.12.2016

Page 2: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE 2

HIPAA and ACA Timeline: 2013 to 2018

ICD-10

ASC X12N Version 7030

Operating Rules

Attachments

Health Plan Identifier (HPID)

Health Plan Certification

Meaningful Use Stage 3 (MU3)

Table of Contents

Page 3: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE 3

HIPAA and ACA Timeline

1/1/2014

EFT Standard and

EFT/ERA Operating Rules

Compliance

Enforcement Delay

Health Plan ID use in

Transactions

Compliance

TBD

Attachments Standard

and Operating Rules

Compliance

TBD

Attachments Standard

and Operating Rules

Effective

TBD

Claims, Enrollment,

Authorizations Premium

Payment, Operating Rules

Compliance

TBD

Claims, Enrollment,

Authorizations Premium

Payment, Operating Rules

Effective

2013 2014 2015

Jan

April

July

Oct

Meaningful Use Stage 1 and 2

TBD

Health Plan Eligibility,

Claim Status, EFT, ERA

Certification

TBD

Health Plan Claims,

Enrollment, Attachments,

Premium Payment, Referral

Certification

1/1/2013

Eligibility & Claim

Status Operating Rules

Compliance

Enforcement Delay

Health Plans must

register for HPID

Compliance

Enforcement Delay

Small Health Plans must

register for HPID

Compliance

TBD

Health Plan Eligibility,

Claim Status, EFT, ERA

Penalty Fees

2016 2017-2018

Regulations below have not been published at this time or have been delayed and the dates are to be determined.

These regulations may be effective sometime in 2016 with compliance dates in 2017- 2018.

Meaningful Use Stage 3

10/1/2015

ICD-10

Compliance

ASC X12N v7030 Staggered Public Comment

Page 4: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

ICD-10

4

Page 5: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

After much planning and anticipation, the October 1, 2015 ICD-10 transition deadline has

come and gone. In the few months since implementation, the ICD-10 code set has

become the accepted industry standard and all involved should be proud of the

role they played in this monumental accomplishment.

Change Healthcare is closely monitoring the transition to ICD-10 and, thus far, has seen

positive trends. Our observations and metrics reveal the following:

More than 95% percent of claims submitted to Change Healthcare at the beginning of

February 2016 were coded ICD-10.

Change Healthcare will continue to process ICD-9 for claims with dates of service or

discharge prior to October 1, 2015 to support run-out and amended claims.

Both providers and payers have demonstrated readiness to utilize ICD-10 codes.

A review of ICD-9 and ICD-10 claims to date reveals little variance in trends related to

average payer payment and denial rates.

While isolated issues continue to occur, these issues continue to diminish as

healthcare organizations tweak their systems and identify opportunities for process

improvement.

Please reference the article “ICD-10 So Far, So Good" in Advance Healthcare Network’s

ExecutiveInsight publication for more information.

5

ICD-10 in Retrospect

Page 6: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

ASC X12N Version 7030

6

Page 7: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

ASC X12N Version 7030 – Public Comment

7

ASC X12N Insurance Subcommittee is currently finalizing version 7030 of the health care

Technical Reports Type 3 (TR3’s). It is anticipated that ASC X12N will recommend to HHS

that version 7030 of the HIPAA-mandated transactions be adopted. Over the course of

2016, ASC X12N will be releasing the 7030 TR3’s for public comment. The public comment

schedule will be announced in Q1; watch www.x12.org for more information.

PUBLIC COMMENT PERIOD – KEY FACTS

Public comment periods for the TR3’s will be staggered, beginning in April 2016 and

ending in December 2016.

NOTE: Public comment periods will be held for all 7030 TR3’s, including those

transactions not mandated under HIPAA.

Each public comment period will extend for 60 days.

Staggered approach allows for more focused reviews and hopefully, increased

participation from the industry.

The intent of ASC X12N is to publish all TR3’s together when the public comment cycles

have been completed and all comments considered.

Change Healthcare is actively participating in the standards development process.

ASC X12N v7030 Staggered Public Comment

Page 8: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Operating Rules

8

Page 9: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Change Healthcare Operating Rules Readiness

9

CAQH certifies and awards CORE Certification Seals to entities that create, transmit or use

the administrative transactions addressed by applicable Operating Rules.

CORE Certification means an entity has demonstrated that its IT system or product is

operating in conformance with a specific phase(s) of the Operating Rules.

Change Healthcare is CORE Phase I, Phase II, and Phase III certified, as evidenced by

our Phase III seal.

Link to Change Healthcare’s CORE Phase III Seal.

Link to our CORE Voluntary Certification (Clearinghouses tab).

Link to the Change Healthcare Press Release announcing our certification.

Additional information regarding the Change Healthcare Operating Rules program can be

found on www.HIPAASimplified.com.

Change Healthcare is CORE Phase III Certified which is one of the two

options proposed in the Health Plan Certification NPRM. To become

CORE Phase III certified entities must be CORE-certified on the earlier

phases. Our CORE Phase III certification serves as Change Healthcare’s

exhibit of readiness.

Page 10: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Enforcement Delay

Health Plan ID use in

Transactions

Compliance

TBD

Attachments Standard

and Operating Rules Compliance

TBD

Attachments Standard

and Operating Rules Effective

TBD

Claims, Enrollment,

Authorizations Premium Payment, Operating Rules

Compliance

TBD

Claims, Enrollment,

Authorizations Premium Payment, Operating Rules

Effective

TBD

Health Plan Eligibility,

Claim Status, EFT, ERA Certification

TBD

Health Plan Claims,

Enrollment, Attachments, Premium Payment, Referral

Certification

Enforcement Delay

Health Plans must

register for HPID

Compliance

Enforcement Delay

Small Health Plans must

register for HPIDCompliance

TBD

Health Plan Eligibility,

Claim Status, EFT, ERA

Penalty Fees

2016 2017-2018

Regulations below have not been published at this time or have been delayed and the dates are to be determined.

These regulations may be effective sometime in 2016 with compliance dates in 2017- 2018.

10

• Operating Rules build on applicable HIPAA and other related standards to make adopted

electronic transactions more predictable and consistent.

• Change Healthcare participated with the industry in defining and preparing for the CORE

Phase IV operating rules.

• Phase IV rules did not address Health Claim Attachments, as prescribed under the ACA,

because attachment transaction standards have not yet been established.

Operating Rules – HIPAA and ACA Timeline

Phase IV Operating Rules anticipated in 2016

Page 11: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Regulatory Roadmap – Phase IV Operating Rules

11

In September 2015, CAQH CORE via their voting process, approved the Phase IV

Operating Rules for voluntary certification.

The Phase IV rules define infrastructure, connectivity, and companion guide

requirements for Health Care Claims (837), Health Care Services Review – Request for

Review and Response (278), Benefit Enrollment and Maintenance (834), and Premium

Payment (820) transactions.

The Department of Health and Human Services (HHS) will determine if the new

Phase IV CAQH CORE Operating Rules will be included in any regulatory

mandates.

NEXT STEPS

In February 2016 the National Committee on Vital and Health Statistics (NCVHS),

advisory body to HHS, will conduct a hearing relating to the adoption of the Phase IV

rules.

NCVHS will make a recommendation to the HHS Secretary as appropriate.

HHS is expected to publish a proposed rule with comment period in 2016.

The Change Healthcare Regulatory Program team will begin to flesh out impact areas

and key resources to build out our enterprise Phase IV Operating Rules program

which will inventory, assess gaps, and remediate all impacted products & services

following the published final rule.

Page 12: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Attachments

12

Page 13: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Enforcement Delay

Health Plan ID use in

Transactions

Compliance

TBD

Attachments Standard

and Operating Rules Compliance

TBD

Attachments Standard

and Operating Rules Effective

TBD

Claims, Enrollment,

Authorizations Premium Payment, Operating Rules

Compliance

TBD

Claims, Enrollment,

Authorizations Premium Payment, Operating Rules

Effective

TBD

Health Plan Eligibility,

Claim Status, EFT, ERA Certification

TBD

Health Plan Claims,

Enrollment, Attachments, Premium Payment, Referral

Certification

Enforcement Delay

Health Plans must

register for HPID

Compliance

Enforcement Delay

Small Health Plans must

register for HPIDCompliance

TBD

Health Plan Eligibility,

Claim Status, EFT, ERA

Penalty Fees

2016 2017-2018

Regulations below have not been published at this time or have been delayed and the dates are to be determined.

These regulations may be effective sometime in 2016 with compliance dates in 2017- 2018.

13

The Administrative Simplification provisions under the ACA include adoption of

transaction standards and operating rules for Attachments.

Attachments are electronic documents that support the following transactions:

• Health Care Claims/Encounters (837)

• Health Care Services Review-Request for Review and Response (278)

• Health Care Services Review Notification and Acknowledgment (278).

A proposed rule establishing Attachment standards is anticipated in late 2016.

CAQH CORE has indicated that development of operating rules for attachments will be

started once HHS establishes transaction standards.

Attachments – HIPAA and ACA Timeline

Proposed Rule for Attachment standards

anticipated in 2016

Page 14: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE 14

Two Standards Development Organizations, Health Level 7 (HL7) and

ASC X12, have been collaborating on the development of Attachments

standards.

HL7 is finalizing the Supplemental Specification for Attachments, which

describes the use of the HL7 Consolidated CDA R2.1 document type

specification for Health Claim Attachments.

Change Healthcare continues to work with the Standards Development

Organizations on the Implementation Guides for these transactions.

The Standards Development Organizations, together with other

industry groups such as WEDI and CAQH CORE, are currently

preparing their testimonies to the National Committee on Vital and

Health Statistics (NCVHS), advisory body to HHS, in a hearing to be

held in February 2016.

ASC X12, HL7, and WEDI are developing a “How To” white paper to

help implementers understand how the ASC X12 and HL7 Attachment

standards work together.

Attachments – Current Activities

Page 15: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE 15

Testimonies to NCVHS are expected to recommend that HHS establish the following

Attachment standards:

Attachments Envelope

- ASC X12N Additional Information to Support a Health Care Claim or Encounter (275)

- ASC X12N Additional Information to Support a Health Care Services Review (275)

- Allow other methods by trading partner agreement

ASC X12N Health Care Claim Request for Additional Information (277RFAI)

- To request additional information to support a health care claim or encounter

HL7 Consolidated CDA (C-CDA) Specification R2.1

- Unstructured Document Type (mandatory support)

- Structured Document Types (optional or phased support)

HL7 Supplemental Specification for Attachments

- Describes use of the C-CDA R2.1 document type specification for Attachments

HL7 Clinical Documents for Payers Set 1 (optional)

Logical Observation Identifiers Names and Codes (LOINC)

- To identify Attachment types and data content.

Acknowledgments

Attachments – Recommendations

Page 16: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE 16

The HL7 Supplemental Specification For Attachments due to be published in

Q2 2016.

Conformance Version of the Supplemental Specifications for Attachments

balloted by HL7 in early May 2016.

NCVHS Hearings to be held on February 16, 2016.

NCVHS Letter of Recommendation expected Q2 2016.

Proposed rule expected Q3 2016.

Final Rule may be issued as early as Q4 2016 with an implementation period

and compliance date of up to two years following final rule publication.

Attachments – Regulatory Roadmap

Page 17: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Health Plan Identifier

(HPID)

17

Page 18: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Enforcement Delay

Health Plan ID use in

Transactions

Compliance

TBD

Attachments Standard

and Operating Rules Compliance

TBD

Attachments Standard

and Operating Rules Effective

TBD

Claims, Enrollment,

Authorizations Premium Payment, Operating Rules

Compliance

TBD

Claims, Enrollment,

Authorizations Premium Payment, Operating Rules

Effective

TBD

Health Plan Eligibility,

Claim Status, EFT, ERA Certification

TBD

Health Plan Claims,

Enrollment, Attachments, Premium Payment, Referral

Certification

Enforcement Delay

Health Plans must

register for HPID

Compliance

Enforcement Delay

Small Health Plans must

register for HPIDCompliance

TBD

Health Plan Eligibility,

Claim Status, EFT, ERA

Penalty Fees

2016 2017-2018

Regulations below have not been published at this time or have been delayed and the dates are to be determined.

These regulations may be effective sometime in 2016 with compliance dates in 2017- 2018.

18

• On 10/31/14 CMS announced an HPID enforcement discretion delay until further notice.

• With clarification that HPID does not replace PayerID, the impact of implementing HPID

has been significantly reduced.

• Change Healthcare has enabled “dual use” support of HPID data content in claim

transactions.

• Industry dialog continues with regard to removing HPID/OEID in healthcare

transactions.

Health Plan ID – HIPAA and ACA Timeline

Regulatory clarifications/revisions

expected in 2016.

Page 19: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Regulatory Roadmap – Health Plan ID

19

Since the HPID final rule was issued in 2012, there have been growing industry concerns

surrounding the regulation, including (1) lack of clarity of the purpose and function of the

HPID, (2) the requirement to use the HPID in HIPAA transactions, and (3) the definition

of health plan versus payer.

Additionally, the National Committee on Vital and Health Statistics (NCVHS), a

governmental advisory body to the Department of Health and Human Services (HHS),

recommended that the HPID not be used in HIPAA transactions.

On May 29, 2015, HHS issued a Request for Information soliciting public comments on

the requirements set forth in the HPID final rule.

The public comment period ended July 28, 2015.

Change Healthcare participated and submitted comments in response to the RFI.

HHS has not yet communicated further regulatory action based on the feedback.

Related Materials

ASC X12 updated errata in HIPAA transactions

WEDI Issue Brief clarifying Payer vs. Health Plan

Page 20: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Health Plan Certification

20

Page 21: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Enforcement Delay

Health Plan ID use in

Transactions

Compliance

TBD

Attachments Standard

and Operating Rules Compliance

TBD

Attachments Standard

and Operating Rules Effective

TBD

Claims, Enrollment,

Authorizations Premium Payment, Operating Rules

Compliance

TBD

Claims, Enrollment,

Authorizations Premium Payment, Operating Rules

Effective

TBD

Health Plan Eligibility,

Claim Status, EFT, ERA Certification

TBD

Health Plan Claims,

Enrollment, Attachments, Premium Payment, Referral

Certification

Enforcement Delay

Health Plans must

register for HPID

Compliance

Enforcement Delay

Small Health Plans must

register for HPIDCompliance

TBD

Health Plan Eligibility,

Claim Status, EFT, ERA

Penalty Fees

2016 2017-2018

Regulations below have not been published at this time or have been delayed and the dates are to be determined.

These regulations may be effective sometime in 2016 with compliance dates in 2017- 2018.

Would require Health Plans to certify data and information systems are in

compliance with applicable standards and operating rules.

Dependent on Health Plan ID regulatory clarifications and revisions.

CAQH CORE is proposed as the certifying entity and there are 2 methods proposed by

which a Health Plan can certify:

1. CORE Certification Seal – existing CORE certification process.

2. HIPAA Credential – under development.

Health Plan Certification – HIPAA and ACA

Timeline

21

Health Plan Certification regulatory clarifications / revisions

expected in 2016.

CHANGE HEALTHCARE IS CORE PHASE I, II, AND III CERTIFIED

Page 22: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Regulatory Roadmap – Health Plan Certification

22

Proposed Rule

Outlines Health Plan definitions and requirements for Controlling Health Plans (CHPs)

and Sub Health Plans (SHPs).

Outlines applicable penalties and fees based on covered lives.

Controlling Health Plans are required to certify compliance.

CAQH CORE has been proposed as the certifying entity.

Page 23: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Meaningful Use Stage 3

23

Page 24: HIPAA and ACA Timeline Change Healthcare Quarterly Updates

PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

Meaningful Use Stage 3 – Regulatory Roadmap

24

On October 16, 2015 a final rule with comment period was published that establishes

modifications to meaningful use in 2015 through 2017 and specifies the requirements that

eligible entities must meet in order to qualify for Medicare and Medicaid Electronic Health

Record (EHR) incentive payments. The final rule with comment can be viewed here.

On April 14, 2015, President Obama signed the Medicare Access and CHIP

Reauthorization Act (MACRA) into law. The MACRA makes three important changes to

how Medicare pays those who give care to Medicare beneficiaries. These changes

include:

- Ending the Sustainable Growth Rate (SGR) formula for determining Medicare

payments for health care providers’ services.

- Making a new framework for rewarding health care providers for giving better care not

just more care.

- Combining existing quality reporting programs into one new system.

Proposed regulations under MACRA are expected to be published in March 2016. The

CMS blog post “EHR Incentive Programs: Where We Go Next” by Andy Slavitt (CMS Acting

Administrator) and Karen DeSalvo (HHS Acting Assistant Secretary for Health) can be found

here.

Meaningful Use Stage 3


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