HIPAA and ACA Timeline Change Healthcare Quarterly Updates

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Transcript of 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

  • 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

  • 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

  • PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

    ICD-10

    4

  • 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 Networks

    ExecutiveInsight publication for more information.

    5

    ICD-10 in Retrospect

    http://healthcare-executive-insight.advanceweb.com/Features/Articles/ICD-10-So-Far-So-Good.aspx

  • PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

    ASC X12N Version 7030

    6

  • 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 (TR3s). 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 TR3s 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 TR3s will be staggered, beginning in April 2016 and

    ending in December 2016.

    NOTE: Public comment periods will be held for all 7030 TR3s, 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 TR3s 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

    http://www.x12.org/

  • PROPRIETARY & CONFIDENTIALCHANGE HEALTHCARE

    Operating Rules

    8

  • 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 Healthcares 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 Healthcares

    exhibit of readiness.

    https://www.changehealthcare.com/news/certificationshttp://www.caqh.org/core/core-certified-organizations-pending-and-currenthttp://emdeon.mediaroom.com/index.php?s=43&item=172http://www.hipaasimplified.com/

  • 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

  • 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

    whi