HIPAA and ACA Timeline Change Healthcare Quarterly Updates

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1 HIPAA and ACA Timeline Change Healthcare Quarterly Updates Q Update Published: May 13, 2016 Q Update Available: No later than August 12, 2016

2 Table of Contents HIPAA and ACA Timeline: 2013 to 2018 ASC X12N Version 7030 Operating Rules Attachments Health Plan Identifier (HPID) Health Plan Certification Implementation of MACRA 2

3 Jan April July Oct HIPAA and ACA Timeline /1/2014 EFT Standard and EFT/ERA Operating Rules Compliance 10/1/2015 ICD-10 Compliance ASC X12N v7030 Staggered Public Comment Meaningful Use Stage 1 and Regulations below have not been published at this time or have been delayed and the dates are to be determined. These regulations may be effective sometime in 2016 with compliance dates in Enforcement Delay Health Plans must register for HPID Compliance Enforcement Delay Small Health Plans must register for HPID Compliance Enforcement Delay Health Plan ID use in Transactions Compliance TBD Health Plan Eligibility, Claim Status, EFT, ERA Certification TBD Health Plan Eligibility, Claim Status, EFT, ERA Penalty Fees TBD Health Plan Claims, Enrollment, Attachments, Premium Payment, Referral Certification TBD Claims, Enrollment, Authorizations Premium Payment, Operating Rules Effective TBD Claims, Enrollment, Authorizations Premium Payment, Operating Rules Compliance TBD Attachments Standard and Operating Rules Effective TBD Attachments Standard and Operating Rules Compliance Implementation of MACRA 3

4 ASC X12N Version

5 ASC X12N Version 7030 Public Comment ASC X12N v7030 Staggered Public Comment ASC X12N Insurance Subcommittee is currently finalizing version 7030 of the health care Technical Reports Type 3 (TR3 s). It is anticipated that ASC X12N will recommend to HHS that version 7030 of the HIPAA-mandated transactions be adopted. Beginning in 2016, ASC X12N will be releasing the 7030 TR3 s for public comment. The public comment schedule will be announced soon; watch for more information. PUBLIC COMMENT PERIOD KEY FACTS Public comment periods for the TR3 s will be staggered, occurring in cycles of 60 days each. Public comment periods will be held for all 7030 TR3 s, including those transactions not mandated under HIPAA. Staggered approach allows for more focused reviews and hopefully, increased participation from the industry. The intent of ASC X12N is to publish all TR3 s together when the public comment cycles have been completed and all comments considered. Change Healthcare is actively participating in the standards development process. 5

6 Operating Rules 6

7 Change Healthcare Operating Rules Readiness Change Healthcare is CORE Phase III Certified which is one of the two options proposed in the Health Plan Certification NPRM. To become CORE Phase III certified entities must be CORE-certified on the earlier phases. Our CORE Phase III certification serves as Change Healthcare s exhibit of readiness. CAQH certifies and awards CORE Certification Seals to entities that create, transmit or use the administrative transactions addressed by applicable Operating Rules. CORE Certification means an entity has demonstrated that its IT system or product is operating in conformance with a specific phase(s) of the Operating Rules. Change Healthcare is CORE Phase I, Phase II, and Phase III certified, as evidenced by our Phase III seal. Link to Change Healthcare s CORE Phase III Seal. Link to our CORE Voluntary Certification (Clearinghouses tab). Link to the Change Healthcare Press Release announcing our certification. Additional information regarding the Change Healthcare Operating Rules program can be found on 7

8 Operating Rules HIPAA and ACA Timeline Phase IV Operating Rules anticipated in 2016 Operating Rules build on applicable HIPAA and other related standards to make adopted electronic transactions more predictable and consistent. Change Healthcare participated with the industry in defining and preparing for the CORE Phase IV operating rules. Phase IV rules did not address Health Claim Attachments, as prescribed under the ACA, because attachment transaction standards have not yet been established. 8

9 Regulatory Roadmap Phase IV Operating Rules In September 2015, CAQH CORE via their voting process, approved the Phase IV Operating Rules for voluntary certification. The Phase IV rules define infrastructure, connectivity, and companion guide requirements for Health Care Claims (837), Health Care Services Review Request for Review and Response (278), Benefit Enrollment and Maintenance (834), and Premium Payment (820) transactions. The Department of Health and Human Services (HHS) will determine if the new Phase IV CAQH CORE Operating Rules will be included in any regulatory mandates. NEXT STEPS In February 2016 the National Committee on Vital and Health Statistics (NCVHS), advisory body to HHS, conducted a hearing relating to the adoption of the Phase IV rules. NCVHS will make a recommendation to the HHS Secretary as appropriate. HHS is expected to publish a proposed rule with comment period in The Change Healthcare Regulatory Program team will begin to flesh out impact areas and key resources to build out our enterprise Phase IV Operating Rules program which will inventory, assess gaps, and remediate all impacted products & services following the published final rule. 9

10 Attachments 10

11 Attachments HIPAA and ACA Timeline Proposed Rule for Attachment standards anticipated in late 2016 The Administrative Simplification provisions under the ACA include adoption of transaction standards and operating rules for Attachments. Electronic Attachments are electronic transactions that support the following: Health Care Claims/Encounters (837) Health Care Services Review-Request for Review and Response (278) Health Care Services Review Notification and Acknowledgment (278). A proposed rule establishing Attachment standards is anticipated in late CAQH CORE has indicated that development of operating rules for attachments will be started once HHS establishes transaction standards. 11

12 Attachments Current Activities Two Standards Development Organizations, Health Level 7 (HL7) and ASC X12, have been collaborating on the development of Attachments standards. HL7 is finalizing the Implementation Guide for Attachments, which describes the use of the HL7 Consolidated CDA R2.1 document type specification for Health Claim Attachments. Change Healthcare continues to work with the Standards Development Organizations on the Implementation Guides for these transactions. ASC X12, HL7, and WEDI are developing a How To white paper to help implementers understand how the ASC X12 and HL7 Attachment standards work together. 12

13 Attachments Recommendations On February 16, 2016, the National Committee on Vital and Health Statistics (NCVHS), advisory body to HHS, conducted hearings on the Attachment standards. Testimonies by clearinghouse representatives recommended adoption of the following: Attachments Envelope - ASC X12N Additional Information to Support a Health Care Claim or Encounter (275) - ASC X12N Additional Information to Support a Health Care Services Review (275) - Allow other methods by trading partner agreement ASC X12N Health Care Claim Request for Additional Information (277RFAI) - To request additional information to support a health care claim or encounter HL7 Consolidated CDA (C-CDA) Specification R2.1 - Unstructured Document Type (mandatory support) - Structured Document Types (optional or phased support) HL7 Supplemental Specification for Attachments - Describes use of the C-CDA R2.1 document type specification for Attachments HL7 Clinical Documents for Payers Set 1 (optional) Logical Observation Identifiers Names and Codes (LOINC) - To identify Attachment types and data content. Acknowledgments 13

14 Attachments Regulatory Roadmap The HL7 CDA R2 Attachment Implementation Guide: Exchange of C-CDA Based Documents, Release 1 to be published in Q Conformance Version of the Supplemental Specifications for Attachments balloted by HL7 in early May NCVHS Hearing was held on February 16, NCVHS Letter of Recommendation expected Q Proposed rule expected Q Final Rule may be issued as early as Q with an implementation period and compliance date of up to two years following final rule publication. Debbi Meisner will be presenting on Attachments at the WEDI Annual National Conference May 23-26,

15 Health Plan Identifier (HPID) 15

16 Health Plan ID HIPAA and ACA Timeline Regulatory clarifications/revisions expected in On 10/31/14 CMS announced an HPID enforcement discretion delay until further notice. With clarification that HPID does not replace PayerID, the impact of implementing HPID has been significantly reduced. Change Healthcare has enabled dual use support of HPID data content in claim transactions. Industry dialog continues with regard to removing HPID/OEID in healthcare transactions. 16

17 Regulatory Roadmap Health Plan ID Since the HPID final rule was issued in 2012, there have been growing industry concerns surrounding the regulation, including (1) lack of clarity of the purpose and function of the HPID, (2) the requirement to use the HPID in HIPAA transactions, and (3) the definition of health plan versus payer. Additionally, the National Committee on Vital and Health Statistics (NCVHS), a governmental advisory body to the Department of Health and Human Services (HHS), recommended that the HPID not be used in HIPAA transactions. On May 29, 2015, HHS issued a Request for Information soliciting public comments on the requirements set forth in the HPID final rule. The public comment period ended July 28, Change Healthcare participated and submitted comments in response to the RFI. HHS has not yet communicated further regulatory action based on the feedback. Related Materials ASC X12 updated errata in HIPAA transactions WEDI Issue Brief clarifying Payer vs. Health Plan 17

18 Health Plan Certification 18

19 Health Plan Certification HIPAA and ACA Timeline Health Plan Certification regulatory clarifications / revisions expected in Would require Health Plans to certify data and information systems are in compliance with applicable standards and operating rules. Dependent on Health Plan ID regulatory clarifications and revisions. CAQH CORE is proposed as the certifying entity and there are 2 methods proposed by which a Health Plan can certify: 1. CORE Certification Seal existing CORE certification process. IS CORE PHASE I, II, AND III CERTIFIED 2. HIPAA Credential under development. 19

20 Regulatory Roadmap Health Plan Certification Proposed Rule Outlines Health Plan definitions and requirements for Controlling Health Plans (CHPs) and Sub Health Plans (SHPs). Outlines applicable penalties and fees based on covered lives. Controlling Health Plans are required to certify compliance. CAQH CORE has been proposed as the certifying entity. 20

21 Implementation of MACRA 21

22 Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Implementation of MACRA On April 16, 2015, the Medicare Access and CHIP Reauthorization Act (MACRA) was enacted into public law. The MACRA makes important changes to how Medicare pays those who give care to Medicare beneficiaries. On April 27, 2016, HHS issued a press release announcing a proposed rule for the implementation of MACRA. The rule establishes a unified framework called the CMS Quality Payment Program, that rewards value and outcomes in one of two ways: - Merit-based Payment System (MIPS), and - Advanced Alternative Payment Models (APMs) HHS will accept comments on the proposed rule until June 27, If finalized, it would replace the current Meaningful Use program and the first performance period would start in 2017 for payments adjusted in The CMS blog post Moving toward improved care through information by Andy Slavitt, CMS Acting Administrator, and Dr. Karen DeSalvo, National Coordinator, Office of the National Coordinator for Health IT, can be found here. 22