(2/8/99) - Letter on Attachments to HCFA

February 8, 1999

Ms. Karen Trudel
Security and Standards Group
Office of Information Services
Health care Financing Administration
7500 Security Blvd., Mail Stop N2-14-26
Baltimore, MD 21244-1850

Dear Ms. Trudel,

I am writing to you on behalf of the Workgroup for Electronic Data Interchange (WEDI).  It is our understanding that the Administrative Simplification Attachment Standard Workgroup will be recommending the ANSI ASC X12N standard 275 for attachments and the 277 for information requests.  The standards chosen will support HL7 and will presumably accommodate six attachments including ambulance claims, emergency room notes, rehabilitation services, laboratory notes, medications and other notes.

For purposes of clarification, WEDI defines attachment information as follows;

1.)  information that tends to be highly situational in nature, being requested only for specific types of services; and
2.)  information that cannot be readily accommodated in a standardized paper or electronic claims format.

WEDI believes that consistent with the statutory intent of Administrative Simplification, standard claims attachments are important for simplifying claims processing.  While providers may be required to submit attachments in response to a specific payer query, providers should have the ability to submit attachments at the time of claim submission.  In addition, for those transactions where it is appropriate, it would be advantageous to permit submission of attachments in either free text, other appropriate digital format and/or structured messages.  It is also WEDI s position that since fewer attachments are preferred as opposed to more, it would simplify the process to standardize when attachments are to be required, and not just how they are to be submitted.

WEDI further believes that standardization and electronic exchange of attachment information could reduce the workload for both the requester and the respondent to attachments. This could ultimately result in cost savings with the electronic exchange of attachment information.

We support the direction you are pursuing in the area of attachment standards, and would be pleased to provide you with any information or assistance as appropriate.

Yours truly,

Lee Barrett
Chairman