(6/20/97) - Letter to Secretary Shalala RE: NSF/UB92 Flat File vs. ASC X12N 837 Claim Standard

June 20, 1997

The Honorable Donna E. Shalala
Secretary of Health and Human Services
440D Hubert Humphry Building
200 Independence Avenue, SW
Washington, DC 20201

Re: NSF/UB92 Flat File vs. ASC X12N 837 Claim Standard

Dear Secretary Shalala,

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) designated the Workgroup for Electronic Data Interchange (WEDI) as an advisor to the Department of Health and Human Services in the selection of electronic health care standards. In pursuing this assignment, the WEDI Board of Directors approved the following resolution in November of 1996;

"Resolved that the Workgroup for Electronic Data Interchange believes that for optimal consumer benefit, all organizations participating in the healthcare industry should adopt electronic commerce standards. Such standards, with assurance of privacy and confidentiality safeguards, must result in business practices that are cost-effective, reduce administrative costs, assure access to patient care, and work towards improving the quality of healthcare; and be it further resolved that WEDI endorses the development and maintenance of standards that can be broadly supported and implemented, and which will enable full healthcare industry participation in electronic commerce."

Additionally, the WEDI policy recommends that the National Uniform Claim Committee (NUCC), National Uniform Billing Committee (NUBC) and American Dental Association (ADA) be recognized as the appropriate organizations to specify data content for those portions of the administrative simplification legislation within their scope.

Subsequent to this action, and following a meeting with representatives from the HHS Secretary s office and ASC X12N, it was agreed that WEDI would convene a broad-based national meeting of healthcare industry officials for the purpose of building consensus on the complex and important claim standard issue. Healthcare industry leaders were invited that represented a majority of the business in their respective markets. A meeting was organized and held in Chicago on March 25, 1997. Ernst & Young served as facilitators for the meeting which was hosted by IBM at their Chicago headquarters. The attendees represented physician practice management vendors, hospital systems vendors, national clearinghouses, payer and provider organizations, as well as representatives from ASC X12N and WEDI. Discussion was focused on solutions that would support the objectives expressed by WEDI in its current policy statements on healthcare standards.

Following several hours of excellent and comprehensive discussion, it was the strong consensus of the participating industry officials to propose the following:

To recommend that the healthcare industry adopt the ASC X12N 837 claim standard as the uniform claims electronic messaging standard of the future for medical, dental and institutions;

To follow the timeline as outlined in the HIPAA legislation. Major healthcare industry plans will be allowed two years from the date of the issuance of pertinent standards to implement the standard X12 837 format. Smaller plans will be allowed an additional year to implement.

To allow an exception for willing trading partners to extend the timeline by an additional two years, if the partnership is in place before the implementation date specified in HIPAA. Therefore the real deadline for these trading partners becomes four years (five years for smaller plans) after promulgation of pertinent standards.

The organizations listed below wish to express their support of the above consensus recommendation regarding the ASC X12N 837 claim standard, and urge your thoughtful consideration and adoption of this proposal.

American National Standards Institute
ASC X12N
Envoy-NEIC
National Data Corporation
EDI USA
Electronic Data Systems
Blue Cross and Blue Shield Association
United HealthCare Corporation
CIGNA Healthcare
Shared Medical Systems
Corporation Physician Computer Network, Inc.
IDX Systems Corporation
Medical Manager Corporation
Medic Computer Systems, Inc.
American Dental Association
American Medical Association
Prudential Insurance Co.
Workgroup for Electronic Data Interchange

The WEDI Board of Directors has approved this proposed recommendation, and joins with the participating organizations listed above, in submitting this to you for your consideration. I would be pleased to provide you with any additional information of benefit on this issue, and welcome any comments or suggestions you might wish to offer for WEDI to further evaluate.

Sincerely,

Ernest Clevenger Chairman