It is a known fact that providers, payers, and vendors are running late with their HIPAA 5010 transition , but things may be even worse than it appears. Only 12% of providers, in fact, have formally initiated their HIPAA 5010 conversions, according to HIMSS, and they're facing a deadline prior to the January 1, 2012 compliance mandate.
“A lot of providers look at 5010 as a project to start in 2010,” says Joe Miller, director of e-business at AmeriHealth Mercy Family Companies. But the first deadline, known as Level 1, is to start trading partner testing on January 1, 2011. “Providers are aware of 5010 but focused on the final compliance date. Many won't be ready to meet the Level 1 compliance.”
That's not to say it's too late, as the month of March winds down, but instead that providers will need to get started pretty much immediately to meet the Level 1 deadline, thereby leaving 2011 for external testing.
During a HIMSS Webinar on Wednesday, Betsy Clore, a senior analyst and programmer at Wake Forest University Health Sciences, and Gale Scott, HIPAA transaction compliance administrator at Tampa General Hospital, outlined 8 steps for getting started.
1. Educate yourself
this begins with getting a clearer understanding of HIPAA 4010 transactions to learn more about the changes in 5010, Wake Forest's Clore says. “And don't assume that X12 is just for techies,” she added. The transition also includes business and regulatory processes, clinical data needs, and even marketing.
2. Analyze changes
Clore recommends the implementation guidelines and the X 12 HIPAA Interpretation Portals as starting points. Changes to consider are impacts to business processes and software, billing procedures, and EDI processes. In Wake Forest's case, converting software and EDI technologies enabled them to use new non-HIPAA 5010 features they did not take advantage of before they upgraded.
3. Communicate with your vendors
Tampa General's Scott explains that by January 1, 2011, providers should be ready to start trading partner testing – and that means vendors have to be on board by then. “Make your vendor aware of your requirements,” Clore adds. “Don't assume that others have covered everything.”
4. Communicate with trading partners
This one is critical because even if you are prepared, a non-compliant trading partner can be trouble. Scott says that a CMS unit will be conducting “random audits to make sure you're compliant.” Fines or other penalties have not yet been detailed but, Scott adds,” There’s every indication they're headed that way.” Clore and Scott recommend understanding partners' timetables and the ways in which testing will be conducted.
5. Upgrade and test vendor software internally
this year is the one for internal upgrades and testing. Remember to “ensure that your 4010 transactions still work,” as you move to 5010, Clore says. In some instances, both Clore and Scott say that their systems work with both 4010 and 5010 transactions, but that depends on the vendor.
6. Update your own customizations and edits
Examples include edits requiring subscriber date of birth and sex, which are no longer needed, as well as some alterations that will need to happen post-compliance, such as turning off the pop-up prompt for patient weight for epoetin, Clore notes.
7. Use a validation service
If you don't already, Clore recommends tapping a validation service to confirm that your transactions are compliant with implementation guidelines. Some services, Clore adds, also handle business edits.
8. Test with trading partners as part of a phased migration
Scott describes the phased migration as “targeted testing of transactions within a full production environment with a gradual transition to full production with one high-volume payer at a time.” Clore says that Wake Forest plans to use just that approach.
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