Health Information Management

My facility applied for the one-year extension to the transactions and code sets compliance date. Do we have to complete all testing by April?

HIPAA Weekly Advisor, January 10, 2003

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Q: My facility applied for the one-year extension to the transactions and code sets compliance date. Do we have to complete all testing by April?

A: If you applied for the extension, you must begin testing by April, but that does not mean that you have to be completely finished with all of your remediation efforts.

Take the following four-step approach to testing:

  • Internal testing. Make sure your solution works.
  • Certification testing. Find an organization to certify that your facility can submit compliant transactions. CMS has selected Claredi as their certification vendor of choice.
  • Practice. Bounce a few files back and forth with a strong partner
  • Trading partner testing. Test with all partners once you're comfortable with one partner

Encourage business partners to test. This way, they have an opportunity to bounce transactions off somebody, before you start trying to trade information, and they send a file you can't even open.

Expect testing to be an ongoing process. If you finish trading partner testing by the end of April, but your vendor doesn't provide an updated version of the software with the final transactions and codes sets changes until June, you have to test again. And if there are more changes, you'll have to test another time.

Editor's note: Answered by Chris Apgar, CISSP, HIPAA compliance officer at Providence Health Plan, in Beaverton, OR, and adapted from the January 2003 issue of Briefings on HIPAA.



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