CMS Initiates 90-Day Enforcement Discretion for 5010 Compliance

January 1, 2012, is the date for covered entities to achieve compliance with ASC X12 Version 5010, NCPDP Telecom D.0, and NCPDP Medicaid Subrogation 3.0 transaction standards. Covered entities include healthcare providers, health plans, and healthcare clearinghouses. Small health plans have until January 1, 2013, to comply with the NCPDP Medicaid Subrogation 3.0 standard. The Center for Medicare & Medicaid Services (CMS) Office of E-Health Standards and Services (OESS) is responsible for enforcement of compliance with electronic transaction standards.  CMS announced on November 17, 2011, that “[w]hile enforcement action will not be taken [from January 1-March 31, 2012], OESS will continue to accept complaints associated with compliance with Version 5010,…

READ MORE

Physical Safeguard Standard, Workstation Security-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the third Physical Safeguard Standard, Workstation Security.  The implementation specification for this standard is defined by the standard title, and is required.  As we have noted in earlier postings on HIPAA.com, business associates of covered entities will be required to comply with the Security Rule safeguard standards, beginning February 17, 2010.  This requirement is one of the HITECH Act provisions of the American Recovery and Reinvestment Act (ARRA), signed by President Obama on February 17, 2009. What to Do A covered entity must implement physical safeguards for all workstations that access electronic protected health information to restrict access…

READ MORE

Information Access Management: Isolating Healthcare Clearinghouse Functions-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the first implementation specification for the Administrative Safeguard Standard (Information Access Management). This implementation specification is required. What to Do If a healthcare clearinghouse is part of a larger organization, the clearinghouse must implement policies and procedures that protect the electronic protected health information of the clearinghouse from unauthorized access by the larger organization. Remember, a clearinghouse is defined as a covered entity, but also can serve in the role of a business associate to other covered entities, namely a health plan or healthcare provider. How to Do It This implementation specification is required, but is not likely…

READ MORE