Lin,
As
I've expressed to you in the past, the National Medicaid EDI HIPAA (NMEH)
Workgroup, which includes all the state Medicaid agencies, has strong and valid
reasons for requiring providers to bill NDCs on the 837s. We have
opposed the elimination of NDCs from the transactions every time someone has
attempted to remove them. The DSMO change control decisions for each of
the NDC change requests were finalized with a decision that NDCs were required
for Medicaid. The fact that this statement did not get added to the
Addenda appropriately does not diminish Medicaids' needs for NDCs on the
837s.
The
NPRMs and Addenda also did not eliminate NDCs from the 837s. They only
removed the standard for billing NDCs. The fact that they failed to name
any standard leaves it open to the payers to determine their standard. The
current addenda do not prevent any payer from requiring providers to bill NDCs
in the NDC Loop in support of their needs for this information. In fact,
this approach provides a quality solution for COB processing where other payers
may not require NDC billing. In these situations, each payer sees what the
previous payer paid for the service regardless of their billing and payment
policies.
Expect
Medicaid Agencies to continue to fight any efforts to eliminate NDCs and other
key data elements from the transactions. If you want HIPAA to work, it
needs to work for everyone. HIPAA compliance is expensive for everyone,
but no more so than for Medicaid agencies who provide services that do not fall
into the normal claims arena. Medicaid agencies are working hard to
comply with the HIPAA standards, but efforts like these to eliminate NDCs,
Taxonomy, and other key elements in midstream could easily become HIPAA
busters.
Alternative solutions for NDCs will cost us in
developing changes to our design, will impact our already tight development
schedule, and will create significant losses in cost containment and rebate
revenues that we have been banking on. Further, our current designs are
very dependent on Taxonomy, and elimination of this element (if the efforts
succeed on the 837I) will require extensive and expensive changes that may not
be completed in time for the October 16, 2003 date, and will cause further
losses in cost containment revenues.
If you
want HIPAA to work, it needs to work for everyone!
Walt
Troidl
HIPAA
Project Manager
State of Indiana Office of
Medicaid Policy and Planning-----Original Message-----
From: Quinkert, Lin [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, September 24, 2002 1:25 PM
To: '[EMAIL PROTECTED]'; Quinkert, Lin; [EMAIL PROTECTED]; [EMAIL PROTECTED]; [EMAIL PROTECTED]
Subject: RE: WEDI/SNIP MANAGEMENT! Non-compliance model
To my knowledge the May NPRM withdrawing NDC except for retail pharmacy has not yet be published as final.Lin Quinkert
HIPAA Practice Manager
GovConnect
A Subsidiary of govONE Solutions
33 Bellewood Ct.
New Albany, IN 47150
Cell: (502) 905-1099
Fax: (812) 949-0611
Email: [EMAIL PROTECTED]
www.GovConnect.com-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, September 24, 2002 8:57 AM
To: [EMAIL PROTECTED]; [EMAIL PROTECTED]; [EMAIL PROTECTED]; [EMAIL PROTECTED]
Subject: Re: WEDI/SNIP MANAGEMENT! Non-compliance model
Lin ~ That reminds me...where are we on NDCs? Has any action been taken on the May NPRM regarding eliminating these with the exception of retail pharmacies (did I miss it? Was I having another one of "those" moments?)?
Jean Acevedo, CPC, LHRM
Acevedo Consulting Incorporated
711 Golf Court
Delray Beach, FL 33445-8737
(561) 278-9328
(561) 278-2253 fax
(561) 445-4243 mobile
[EMAIL PROTECTED] (NEW!)
This email and any files transmitted with it are confidential and are intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient, any use, dissemination, forwarding, printing, or copying of this email or any transmitted files is strictly prohibited. If you received this email in error, please notify Acevedo Consulting Incorporated at [EMAIL PROTECTED]m
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discussions on this listserv therefore represent the views of the individual
participants, and do not necessarily represent the views of the WEDI Board of
Directors nor WEDI SNIP. If you wish to receive an official opinion, post
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