How many times were we told that the Health Insurance Portability and Accountability Act (HIPAA) electronic transaction set would be implemented on Oct. 16, 2003? Well, in an effort to allow providers to turn the switch and bill the new ANSI format, it was found that many of our trading partners, for whatever reason, were not ready for the event. So, the Centers for Medicare and Medicaid Services has activated a contingency plan that grants an extension to that well-publicized deadline.
This does not mean that HIPAA is going away. Providers must show a good faith effort in complying with the new electronic guidelines for claims submission. Have you developed a plan? Is your software vendor ready? Are you electronically transmitting now under the ANSI format? Are you ready to deal with an interruption in cash flow due to transmission issues? If you answered “no” to any of these questions, you are not alone.
In speaking to providers across the nation, many who have begun transmitting under the ANSI format have not received payments from the DMERCs for one to two months. Your company should be prepared with a plan on how you are going to handle this cash flow problem. Do you have an adequate line of credit or cash reserves that will allow you to operate for 30 to 60 days? If not, you need to develop a relationship with your financial institution or investors to put such a plan in place.
Have you thought about staffing issues? You may need additional personnel on the telephones to resolve billing issues with various providers.
Identify your largest payers, and communicate with them about how they expect to reimburse you for your services in the event that you cannot transmit claims to them electronically. You may find that some of your trading partners are not ready, and that you need to adjust your business practices accordingly.
Have you begun testing with the DMERCs or other trading partners? If you have not yet tested, the time to do so is now. Call your software vendor to verify that they are certified with all four DMERCs, and find out if you need to update your software to become HIPAA-compliant. This could cost your company extra in support fees, but it may be a necessary expense in conducting business under the new HIPAA guidelines.
If you decide to outsource your billing, make sure to select a company that fits your needs. Talk to the owner and get references. How many years has the company been in business? Does the company have experience specifically with HME and/or pharmacy? How is the billing company structured? What type of training is given to employees? Is the training ongoing?
Do your homework. There are many national billing companies that are in this industry for the right reasons and that give providers what they deserve — the best!
HIPAA is here to stay. If you have not developed a plan to become compliant, it is not too late, and it certainly should not be an issue that makes you feel you should close your doors. Visit the CMS Web site at www.cms.gov to learn more about the development of HIPAA-compliant transactions and the claims submission contingency plan. The site also offers suggestions on the types of things CMS may look at to determine whether you have made a good faith effort to meet the new guidelines.
Make sure you are giving all of your patients a copy of the Notice Of Uses (effective April 15, 2003), and that you have documentation showing you have done so.
Prepare now, so when the next “new” deadline is announced, you will be ready to turn the key.
Jane Bunch is CEO of Kennesaw, Ga.-based JB&CS Inc. A reimbursement specialist, Bunch helps develop compliance plans and serves as a consultant for fraud and abuse cases. She can be reached at 678/445-1221 or by e-mail at BillHME@jbcservices.com.
