On Thursday, November 17, 2011, the CMS Office of E-Health Standards and Services (OESS) announced that it would not initiate enforcement action until March 31, 2012, with respect to any HIPAA covered entity that is not in compliance with the ASC X12 Version 5010 (Version 5010), NCPDP Telecom D.0 (NCPDP D.0), and NCPDP Medicaid Subrogation 3.0 (NCPDP 3.0) standards. Notwithstanding OESS’ discretionary application of its enforcement authority, the compliance date for use of these new standards remains January 1, 2012 (small health plans have until January 1, 2013 to comply with NCPDP 3.0).
CMS’ Office of E-Health Standards and Services is the U.S. Department of Health and Human Services’ component that enforces compliance with HIPAA transaction and code set standards. OESS encourages all covered entities to continue working with their trading partners to become compliant with the new HIPAA standards, and to determine their readiness to accept the new standards as of January 1, 2012. While enforcement action will not be taken, OESS will continue to accept complaints associated with compliance with Version 5010, NCPDP D.0, and NCPDP 3.0 transaction standards during the 90-day period beginning January 1, 2012. If requested by OESS, covered entities that are the subject of complaints (known as "filed-against entities") must produce evidence of either compliance or a good faith effort to become compliant with the new HIPAA standards during the 90-day period.
Infinedi will continue to test with payers with the goal of turning payers over to 5010 production by January 1, 2012. If the payer is requesting an extension we will continue to submit 4010A1 until the payer is ready or the deadline of March 31, 2012. Infinedi will continue to translate your print image or 4010A1 files to meet the 5010 requirements by the payers.
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