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,…

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HHS’ ONC Releases Proposed Rule for Temporary and Permanent HIT Certification Programs

On Wednesday, March 10, 2010, the Office of the National Coordinator for Health Information Technology (ONC) of the Department of Health and Human Services (HHS) published in the Federal Register the Proposed Rule (NPRM) for Proposed Establishment of Certification Programs for Health Information Technology.  [75 Federal Register 11327-11373]  We present the summary of the NPRM. “SUMMARY.  Under the authority granted to the National Coordinator for Health Information Technology (the National Coordinator) by section 3001(c)(5) of the Public Health Service Act (PHSA) as added by the Health Information Technology for Economic and Clinical Health (HITECH ) Act, this rule proposes the establishment of two certification programs for purposes of testing and certifying…

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Contingency Plan: Emergency Mode Operation Plan-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the third implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is required. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Establish (and implement as needed) procedures to enable continuation of critical business processes for protection of the security of electronic protected health information while operating in the emergency mode. How to Do It Covered entities are required to develop…

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