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5010: January 1 Compliance Date Won’t Be Enforced Until March 31

Medicare has announced that it plans to delay enforcement of the 5010 electronic transaction standards—but not the compliance date. (For those of you who lived through the initial HIPAA electronic transactions and code sets implementation in 2003, the announcement may feel like déjà vu.)

On November 17, the Centers for Medicare & Medicaid Services (CMS) Office of E-Health Standards and Services (OESS) issued a press release stating that it will not enforce compliance with the new 5010 transaction standards until March 31, 2012. However, the actual compliance date remains January 1, 2012.

Although the extension provides practices the ability to work through the 5010 transition without severe damage to their revenue cycle, it does not move the compliance deadline. As Pati Hildebrand, executive director of Hildebrand Healthcare Consulting stated in a recent Physicians Practice article, “I’m betting that some organizations will think this means they don’t have to implement HIPAA 5010 for another 90 days, but that would be wrong. Any claims or bills they submit after January 1, 2012, that are not in HIPAA 5010 will still get rejected, but this delay in enforcement will also allow them to resubmit in the appropriate HIPAA 5010 format without penalty.” Click here to read the entire Physicians Practice article.

OESS notes that it intends to start accepting compliance-related complaints in regard to 5010 as originally planned on January 1. Those who are the subject of a complaint between January 1 and March 31 may be required by OESS to demonstrate either compliance or a good faith effort to become compliant with 5010.

Despite this enforcement grace period, I encourage every practice to continue working on their 5010 implementation plan on the schedule they established months ago. The goal should be that your practice is in compliance on or before January 1. This will negate any lag in the revenue cycle or confusion of having to resubmit claims.