Data Transmission and Code Set Rules under HIPAA - Who are the experts

[Christine Roberts]

These rules are very complex and I am wondering who is advising self-insured plans, hospitals, and the like on compliance.

Is it the "turnkey" HIPAA compliance consultants? Attorneys? Information systems experts?

Just wondering.....

[Steve72]

My firm has provided advice on the legal requirements and ramifications, however, as far as the actual technical changes that need to be made, we've deferred to the client's IT department.

The real legwork is a tech issue, not a legal one.

[Guest LRM464]

If an employer sponsors a self-insured group health plan but is not a health care provider (e.g., not a hospital etc.), the employer probably does not need to be able to transmit standard transactions. Rather, the employer wants to be sure the TPA that it is using for its GHP will be able to transmit standard transactions on behalf of the plan. If the TPA is performing the normal claims paying functions for the employer's plan, it's the data transfers between the TPA and providers that have to be compliant, not the data transfers between the employer and the TPA.

Linda

[Steve72]

Linda is absolutely right, but plan sponsors should keep in mind that this TPA will not, itself be a covered entity. The statutory obligation is still the plan's. The plan may meet this obligation by ensuring that the TPA utilizes the proper code sets.

It's a little late now, but any plan (other than a small health plan) that received a notice from a TPA that stated that the TPA will not be compliant by the deadline (2 days ago) should have filed its own extension, or had one filed for them.