HIPAA Model Compliance Extension Plan and Instructions
Now Available

In 1996, the Health Insurance Portability and Accountability Act (HIPAA) became
law. It requires, among other things, that the Department of Health and Human Services
establish national standards for electronic health care transactions and code sets.

October 16, 2002, is the deadline for covered entities such as health plans, clearinghouses and providers (such as physicians, dentists, hospitals, nursing homes
and others) to comply with these new standards.

However, in December 2001, the Administrative Simplification Compliance Act (ASCA, Public Law 107-105) gave covered entities not compliant by October 16, 2002, the opportunity to extend their compliance
deadline by 1 year – to October 16, 2003.

This extension opportunity is applicable to all
HIPAA covered entities other than small health plans (those with less than $5 million in annual receipts whose compliance date is already set for October 16, 2003). In order to qualify for this extension, covered entities must submit a compliance plan by October 15, 2002.

A model compliance plan and instructions on how to complete and submit it are available on the Centers for Medicare & Medicaid Services (CMS) Web site,
www.cms.hhs.gov/hipaa.

You can submit this on-line model plan electronically through the Web site or print and mail it. You can submit your own paper version of the plan as long as it provides equivalent information (covered entity and contact information; reasons for filing for the extension; HIPAA implementation budget information; and where you are in implementing and testing including whether or not you plan to use a vendor). The CMS strongly encourages electronic filing but if you must file on paper, you
should send your form to

Model Compliance Plans
Centers for Medicare & Medicaid Services (CMS)
P.O. Box 8040, Baltimore, MD. 21244-8040.

The deadline for both electronic and paper submissions is October 15, 2002.

If you file electronically through the Web site, you will receive an electronic confirmation number acknowledging and granting your extension. If you file a paper
version, you won’t receive a confirmation, but if your paper plan consists of the required equivalent information, you may consider your extension granted.

The instructions give more details on how to complete the form; explanation of who should file for an extension; data you need to include; and where to get more information on definitions, frequently asked questions, etc. For more information, submit questions to askhipaa@cms.hhs.gov.

Providers Using Medicare Supplied Billing Software

Medicare contractors will continue to provide electronic billing software for providers to use to submit their Medicare claims. The HIPAA compliant version of this software will be available on or near July 15, 2002, from PC-ACE Pro32 ® Support of First Coast
Service Options, Inc. (FCSO). Any providers who will continue to use the non-HIPAA version Medicare billing software at any time between October 16, 2002, and October 16, 2003, must submit a Compliance Extension Plan as described above.

Source: CMS Transmittal AB-02-071, Change Request 2168