One Week from Today: 5010/D.0 Final Rule Effective Date

They’re coming: the Ides of March (the 14th); NCAA Basketball Tournament Announcement (the 15th); St. Patrick’s Day (the 17th); and 5010/D.0 Final Rule Effective Date (the 17th).

If you are a covered entity, Level 1 testing begins Tuesday, March 17, 2009. Here are five things you need to do to start.

Conduct a Gap Analysis. What do I need to do to become compliant on January 1, 2012? That date sounds far off, but it will be here before you know it. Unlike previous transaction contingency periods for covered entities and their trading partners, HHS has indicated that there will be no tolerance for those not ready. Read the final rule, which is on the HIPAA.com site for your convenience.

Contact Your Software Vendor. What is my vendor’s plan, in writing, for achieving internal Level 1 testing by December 31, 2010, and external Level 2 testing with my trading partners by December 31, 2011? HIPAA.com covered the requirements of Level 1 and Level 2 testing, which is available on the HIPAA.com site for your convenience.

Contact Your Trading Partners. What are my trading partners’ plans for achieving Level 1 and Level 2 testing? The final rule permits covered entity-to-trading partner testing and production of new transactions using 5010/D.0 when each is ready, prior to the January 1, 2012 compliance date. Determine the advantages of doing so, such as potential cost savings from implementing electronic remittance and claim status transactions.

Inform Your Workforce Members That Change is Coming. Over the next five years, healthcare covered entities, business associates, and stakeholders will see significant change, not only from 5010/D.0, but also implementation of ICD-10 (also March 17, 2009 effective date and October 1, 2013 compliance date) and new HITECH Act requirements embodied in the February 17, 2009, enactment of the American Recovery and Reinvestment Act (“ARRA”). All workforce members must be onboard to ensure successful implementations and compliance.

Make a Plan. We started with a Gap Analysis to determine what was required to achieve compliance with 5010/D.0. You need another plan, a long-range workflow and competitive analysis. How will my business look like with all of the aforementioned changes? How do workflows change as we introduce more electronic business processes? What new policies and procedures must we adopt? What impact will all of these changes have on my business constituencies and customers? What are the impacts on costs and revenues of my business?

In short, now is the time to start your short- and long-term game plans for adopting new electronic business processes and adapting your workflows. HIPAA.com will provide resources to help you along the way.

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