HHS Publishes Final Rule on Administrative Simplification, Pushes Back ICD-10 Compliance Date


On August 24, 2012, HHS published a final rule standardizing a number processes relating to health care administrative transactions.  The rule adopts the national unique health plan identifier (HPID) standard and establishes requirements for HPID implementation; adopts a data element that will serve as an “other entity” identifier (OEID), which applies to entities that are not health plans, providers or individuals; specifies circumstances under which covered health care providers must require certain noncovered prescribing health care providers to obtain and disclose a National Provider Identifier; and moves the date for covered entities to comply with ICD-10 diagnosis coding from October 1, 2013 to October 1, 2014.

The implementation of HPID is required under the administrative simplification provisions of the Affordable Care Act.  Health plans and other entities performing health plan functions are identified in standard transactions under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) using a number of identifiers that sometimes vary in format.  According to the summary of the rule, the move toward standardization—via the adoption of HPID and OEID—will increase efficiency and reduce errors within HIPAA standard transactions.  For the entire health care industry, the projected savings of implementing HPID over 10 years ranges from $1.3 billion to $6 billion.

With respect to the transition from the ICD-9 to ICD-10 code set, the summary of the rule states that since 2009, when HHS published a final rule adopting ICD-10, provider groups have voiced concerns about their ability to transition to the new system of medical data code sets.  The compliance date set by the 2009 final rule was October 1, 2013.  The one-year delay (to October 1, 2014) will give covered entities more time to move to the new code sets and ensure a “smooth transition” across all industry segments, the rule states.

The final rule will be published in the Federal Register on September 5, 2012, and the regulations will go into effect 60 days later, on November 5, 2012.

Click here to view the final rule.

Reporter, Greg Sicilian, Atlanta, +1 404 572 2810, gsicilian@kslaw.com.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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