WEDI letter to HHS Secretary Thompson requesting expediting of pending standards for Administrative Simplification
March 21, 2002
The Honorable Tommy Thompson
Secretary of Health and Human Services
Hubert Humphrey Building
200 Independence Avenue, SW
Room 615F
Washington, DC 20201
Dear Secretary Thompson:
I am writing to you on behalf of the Board of Directors of the Workgroup for Electronic Data Interchange (WEDI) on three matters relating to the Administrative Simplification standards requirements in the Health Insurance Portability and Accountability Act of 1996 (HIPAA):
- First, to strongly encourage you to accelerate publication of CMS-0005-P (addenda to Transaction Standards). The current delayed process forces covered entities either to implement outdated transaction standards or to declare that they cannot be compliant until HHS publishes the addenda, creating, in both cases, inefficiencies.
· Second, to alert you to the healthcare industry's growing frustration with the continuing delays in publication of Administrative Simplification standards rules generally, and specifically the rule mentioned above along with CMS-0003-P (NDC/J Code usage). Rather than achieving the cost benefits of Administrative Simplification, the healthcare industry is wasting scarce resources as a result of these delays.
- Third, to request an urgent meeting with you personally and with your staff to identify practical solutions, effective measures, and reasonable strategies to accelerate the standards development, review, and approval process. This would enable the federal government and healthcare industry to take steps together to end industry frustration and to achieve in a timely manner successful implementation of Administrative Simplification.
WEDI's membership represents a vast healthcare constituency in the United States. In recognition of its constituency and its role as an early advocate of Administrative Simplification, WEDI was specified in the HIPAA legislation as an advisor to the Secretary on Administrative Simplification matters. In this advisory role, WEDI must inform you that these continuing delays, resulting in a rising crescendo of frustration throughout the healthcare industry, have two immediate consequences:
· Financial/Operating Inefficiencies. Healthcare providers, payers, clearinghouses, and vendors have allocated considerable numbers of personnel and invested significant financial resources for Administrative Simplification preparation and implementation. The delayed issuance of final rules and potential inconsistencies in these rules are creating inefficiencies with respect to achieving compliance and budgeting for compliance. An increasing number of key healthcare stakeholders believe that these financial resources are being wasted, due to standards not being published, and systems and procedures being put in place today that will need to be replaced tomorrow.
· Credibility. The credibility of the Department of Health and Human Services within the healthcare industry has eroded, with a resultant loss of confidence regarding the Department's commitment to the successful fulfillment of Administrative Simplification. WEDI has made repeated offers to the Secretary and HHS, in fulfillment of its advisory role, to facilitate standards development and implementation (see attached chronology and discussion of issues that WEDI has addressed). Appropriate and timely actions have not been taken. WEDI believes that a move toward restoring credibility can be achieved by addressing the matters outlined in the beginning of this letter.
In its 1993 Report, prepared through a collaboration of government and industry at the request of then Secretary of HHS, Louis Sullivan, WEDI reported that the healthcare industry expressed a strong need for Administrative Simplification standards as a means of spurring efficiency and stemming administrative costs in a healthcare cost inflationary environment. No one involved with achieving Administrative Simplification today will doubt that the original goals of spurring efficiency and stemming administrative costs are even more important in today's escalating healthcare cost environment.
WEDI believes that quick action is necessary to alleviate these growing frustrations in the healthcare industry. We look forward to meeting with you at your earliest convenience to discuss these matters. If you have any questions, please contact me at 303-488-9911 or James Schuping, Executive Vice President, at 703-391-2716.
Sincerely,
Steve Lazarus
Chairman; WEDI