HHS lays out timetable for HIPAA requirements

HHS senior advisor Bill Braithwaite recently laid out a timetable for many of the technical requirements that are part of the Health Insurance Portability and Accountability Act.

Here are the key areas he addressed:

  • Identifiers. Braithwaite says there is little disagreement about the employer identification number. "There was absolutely no controversy about this," he says. "When the final rule comes out before the end of this year, we will have adopted the IRS’ [Internal Revenue Service’s] identification number, so you can go ahead as if it were final already."

According to Braithwaite, provider identification numbers are expected in 2001. "It could happen," he says, but the first quarter of 2002 would be more realistic. For plan identifiers, early in 2002 also is the most realistic timeframe, he adds.

"It is pretty clear that both of these are going to be 10-digit numbers, and that is all you really need to know for what you are going to be doing [in the foreseeable future]," he adds. "The longer we hold out on coming up with the final rules for these identifiers, the less you have to worry about them, as long as you know it is going to be a 10-digit number in both cases when you are implementing them for the transaction standards."

According to Braithwaite, the unique identifier for individuals is on hold indefinitely because the public is fearful of the federal government having anything to do with assigning numbers.

That likely means that HHS will continue to use the default unique identifier for individuals — the Social Security number — even though Braithwaite calls that "the worst possible one" to use. "The administration and Congress are both committed to not doing anything about the unique individual identifier, so you can forget that it is even there for the foreseeable future," he says.

  • Electronic medical records information. The National Committee on Vital and Health Statistics has come up with some broad, initial recommendations for HHS. However, Braithwaite predicts it will be another year or two before there actually is a consensus standard for the exchange of patient medical record information between one electronic patient system and another.

That is the level of the standard, he adds. "We are not setting standards for the electronic record systems themselves, just on how they communicate with each other," he explains.

  • Transaction codes. The transaction rule adopts X12N standards for transactions except for retail pharmacy transactions, and adopts the code sets that are commonly used right now, Braithwaite notes. "We took advice that said, "Don’t adopt ICD10 yet," he adds.

Local codes were eliminated, not because HHS does not like them, but simply because they provide no standard, according to Braithwaite. "We need national standard coding systems that can be implemented electronically and used by everyone," he asserts.

The modifications to these standards proposed by the standard developing organizations should be published in December, predicts Braithwaite. If that happens, HHS can respond to those standards, and the final rule can be published in time for HHS to implement them before the compliance date.