Employer-sponsored health plans have a lot of work to do over the next couple of years to ensure continued compliance with HIPAA’s electronic transaction standards. HIPAA’s administrative simplification rules require a health plan to conduct certain electronic transactions in accordance with standards, code sets, and operating rules adopted by the Department of Health and Human Services (“HHS”). The PPACA significantly expands on these standards, code sets, and operating rules. The PPACA also adds the requirements that a health plan (1) obtain a health plan identifier (“HPID”) for the health plan to use with respect to the electronic transaction standards; and (2) certify compliance with the applicable electronic transaction standards.
Thus, under the PPACA’s expansion of HIPAA’s electronic transaction standards, a health plan needs to (1) ensure that it is in compliance with all currently applicable standards and operating rules (and prepare to comply with upcoming standards and operating rules); (2) obtain a HPID by November 5, 2014 (or November 5, 2015 if it is a small health plan); and (3) prepare to certify to HHS that it is in compliance with certain electronic transaction standards by December 31, 2015 (or December 31, 2016 if it is a small health plan).
Continue reading HIPAA – Electronic Transaction Standards – Action Required!
It is crucial for businesses to respond to the changing regulatory landscape, as the Patient Protection and Affordable Care Act (“ACA”) continues to evolve. Some recent updates center around the implementation of various components of the legislation, while others focus on the obligations of individuals and businesses under the new system. The only constant in this process — is that businesses can expect health care reform to continue to evolve over time. Accordingly, business leaders must understand the current regulatory environment and be ready to adapt to future changes.
