The rules resulting from the Health Insurance Portability and Accountability Act (HIPAA) affect practitioners in many substantial ways. Though the privacy rule is by far the most comprehensive of these rules, and the one with the greatest impact on practicing psychologists, there are other HIPAA rules that require practitioners to take action.
Of particular urgency, practicing psychologists must act by Oct. 15 to extend by one year the deadline by which they must comply with the HIPAA transactions rule.
This rule requires practitioners to use a standardized transaction format that all third-party payers will accept for data used to submit electronic claims.
What the transactions rule covers
Congress passed HIPAA in 1996 in part to provide national standards for information exchange in the healthcare system. The standards are intended to improve the efficiency of health-information exchange while ensuring the privacy of patient records. The transactions rule seeks to standardize health information for financial and administrative purposes.
When the rule was released in 1999, it carried a compliance date of October 2002. In December 2001, Congress decided to delay for one year--until October 2003--the date required for transactions rule compliance. However, in order to extend their compliance deadline until October 2003, practitioners must submit a form to the U.S. Department of Health and Human Services by Oct. 15, 2002, describing how they plan to meet the rule's requirements by the October 2003 deadline.
Who must submit a compliance form and why
Psychologists who transmit any health information in electronic form to carry out financial or administrative activity related to health care or who do Medicare and Medicaid work must submit a transactions rule compliance form. Practitioners who use only paper claims theoretically do not have to submit a compliance form. However, those who provide services to Medicare and Medicaid beneficiaries are required by those programs to submit the form. And because the private market is fast moving toward reliance on electronic transactions, the APA Practice Organization and the APA Insurance Trust have produced materials that strongly recommend that all practicing health service psychologists submit the transactions rule compliance form.
What the compliance form includes
The form contains 26 questions and is separated into four sections. The sections ask for contact information, why you are filing for an extension, an estimate of how much it will cost your practice to comply with the transaction rule, and your "implementation strategy." The entire form must be completed even though some of the questions may not apply to a particular practice situation. Government officials describe the form as taking only 10 or 15 minutes to complete.
Where to obtain and submit the form
The Centers for Medicare & Medicaid Services (CMS) of the U.S. Department of Health and Human Services has placed the compliance form online at www.cms.gov/hipaa/hipaa2/ascaform.asp. Practitioners may fill out the form online and submit it electronically.
Those who submit the form electronically will receive a confirmation number as acknowledgment that their compliance deadline has been extended. Practitioners who return their completed form to CMS by mail will not receive a similar acknowledgment. The mailing address for completed forms is: Attention: Model Compliance Plans, Centers for Medicare & Medicaid Services, P.O. Box 8040, Baltimore, MD 21244-8040.
The form must be submitted electronically or postmarked no later than Oct. 15. One health professional may complete and submit a form on behalf of his or her group practice.
Your HIPAA resource
In August, the APA Practice Organization and the APA Insurance Trust sent a mailing with detailed step-by-step instructions and guidance for practicing psychologists about filling out all of the questions on the transaction rule compliance form. Additional information also is available from each organization at APA Practice and www.apait.org/hipaa .
The APA Practice Organization is exploring a number of solutions to help practitioners ensure that their electronically submitted claims are in proper standardized format.
Later this year, the Practice Organization and Insurance Trust will release a comprehensive compliance resource that will provide practitioners with all of the information, forms and policies they need to comply with the HIPAA rule that has the greatest impact on practitioners--the privacy rule.
--THE APA PRACTICE ORGANIZATION and the APA INSURANCE TRUST