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 AOA HIPAA Policy

 
​At the AOA, we have an internal HIPAA privacy policy to enable us to work with AOA members and insurers on coding, reimbursement or managed care problems without utilizing patient-specific, identifiable health information.
 
We are requesting the following with each inquiry from AOA members:
  • Patient records must have all HIPAA-protected health information removed.
  • If the physician must identify the patient, the physician must assign a code number or name to the file.
If the you send us patient-protected health information, we will immediately shred the information and notify you that material must be re-submitted without the patient information.
 
We suggest that each state association and specialty college examine their policies to determine what patient information they use to assist members, and adopt an internal HIPAA privacy policy to prevent violations of HIPAA.
 

 Contact Us

 

Yolanda Doss
ydoss@osteopathic.org
(312) 202-8187

Sandra Peters
speters@osteopathic.org
(312) 202-8088

Kavin Williams
kwilliams@osteopathic.org
(312) 202-8194

HIPAA

​Getting Ready for the HIPAA 5010 Implementation Deadline - Reprieve until March 31, 2012

Take these precautions to avoid disruptions in claims processing and delays in cash flow:

You risk potential disruptions in your practice’s cash flow due to claims denials and/or slow payments if you don’t upgrade and test claims in HIPAA 5010 electronic data transmission standards. CMS recently issued a reprieve until June 30, 2012. This is an extension of an earlier reprieve date of March 31, 2012. The deadline remains Jan 1, 2012; however, CMS will not start enforcing compliance until June 30, 2012. The sooner osteopathic practices comply the better off they will be financially and the less chance of incurring claims processing delays and cash flow disruption.

HIPAA 5010 version requires that all practices either update their practice management information system software or ensure that their billing service and/or clearinghouse has upgraded systems for all claims, claims status requests and responses, eligibility inquiries and remittance advice electronic transactions. This may require installing updated software into your practice management and/or EHR software, changing business operations and workflows, testing internally and externally, and training staff.

One of the biggest changes is that a post office box or lockbox address will not be acceptable in the new 5010 version.

  • Your nine-digit ZIP code is required – 0000 or 9999 will not be recognized.
  • You must furnish nine-digit ZIP codes on the claim. Using the five-digit ZIP code may cause your claim to be rejected.

A second change is that patients given an individual identification number must be noted as a subscriber. If the family health plan provides each dependent child with an ID number you must list their name and ID number instead of listing them as a dependent.

Steps to Avoid Slow or Nonpayment of Claims

1) Assess you practice’s readiness for 5010 conversion. Contact your vendors, payers, billing service, and clearinghouse to see what upgrades they are planning for your systems. Ask what their implementation schedule is, if there is a fee, and if their software is dual-eligible. In other words, if they will be able to perform the new 5010 and the current 4010 at the same time, because not all payers will be ready at the same time. The sample letter below may assist you in getting this information. If you have already upgraded your practice management system software to 5010, test with your top payers individually or through your clearinghouse. Your clearinghouse should be able to guide you through the 5010 requirements. Note that a practice management computer that is more than five years old may not be able to run 5010 software.

2) Install the ICD-10 upgrades and test your systems. Once you have checked in and upgraded to 5010 with your trading partners (clearinghouse, Medicare and Medicaid, private payers and EHR system), you will need to conduct internal and external testing.

Level 1, internal testing will determine if your practice is able to create and receive 5010 compliant transactions. If your practice uses an EHR, the test will determine if you are able to create and receive 5010 compliant transactions. If your practice uses a billing service or clearinghouse and sends them data for them to submit your transactions, your testing should ensure that processes are in place to collect the necessary data that you will then send back to the billing service or clearinghouse.

Level 2, external testing, should be conducted with the trading partners that make up the largest number or revenues for your practice. This may entail testing with Medicare, Medicaid, and commercial payers. Your clearinghouse may indicate that you do not need to test with payers that they will do the testing on your behalf and guarantee payer compliance. External testing will involve sending dummy data to conduct a transaction electronically and receive test data back into your practice. Medicare has indicated that the Medicare Administrative Contractors (MACs) will be ready for 5010. Contact your MAC’s help desk and ask them what their testing plan involves. Don’t wait. There may be a backlog to conduct external testing so test early and avoid a lengthy wait.

3) Assess your budget needed for implementing 5010 and staff training needs. Who in your practice performs coding and billing? Who needs to know the new codes? In addition, to avoid unnecessary disruption, be sure to submit all claims for services rendered by March 31, 2012 to ensure your practice has sufficient funds through March. Remember that as of March 31, 2012 you must use only 5010 transactions. Older transactions will be non-compliant and will be rejected.

 

 Sample Letter for Vendors

 

Dear Vendor (Clearinghouse, EHR system, Medicare, private payers):

My practice uses your (name of product) product/services, version (number). As HIPAA 5010 implementation approaches, we would like some information and clarification about your plans to upgrade your systems. Specifically, we would like to know your plans for updating software to comply with HIPAA transactions.

Can you provide a timetable for the following:

1) When will you be installing upgrades and will there be a charge for this data?

2) Will my practice need additional hardware or support services to install the upgrade(s)?

Thank you in advance for complying with and your prompt attention to this request.

Sincerely,