Regulatory Developments

Are Medicare Part A providers meeting standards imposed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA)? On May 2003, the Office of Evaluations and Inspections (OEI), Office of the Inspector General (OIG), Department of Health and Human Services (HHS) issued a report about the progress made by Medicare Part A providers in meeting various standards imposed by HHS as part of HIPPA implementation. See HIPAA Readiness: Administrative Simplification for Medicare Part A Providers (OEI-09-02-00421). As explained in the report, this study was conducted 'to determine if Medicare Part A providers expect to comply with the electronic data transaction standards and code sets mandated by ' [HIPAA] by October 2003. HIPAA Readiness ' Executive Summary, at 1. As part of its obligations under HIPAA, HHS promulgated regulations requiring that specific standards be used for eight different types of electronic transactions and medical code sets by October 16, 2003. See 45 C.F.R. Parts 160 and 162. The eight types of electronic transactions are:

• Health care claims or equivalent encounter information;
• Health care payments and remittance advice;
• Coordination of benefits;
• Health care claim status;
• Enrollment and disenrollment in a health plan;
• Eligibility for a health plan;
• Health plan premium payments; and
• Referral certification and authorization.

To determine how many providers expect to be ready to comply with this deadline, the OEI evaluated the results of a mail survey of a stratified random sample of Medicare Part A providers that submitted claims to Medicare fiscal intermediaries between July 1, 2001 and June 30, 2002. Id. The results from this sample are promising: Ninety-two percent of Part A providers report having made significant progress in meeting the HIPAA deadline, while another one-half are developing sequencing strategies and contingency plans in the event their system is not fully in compliance with the deadline. Id. at 1-2. The report can be obtained from the OIG's Web site, www.oig.hhs.gov/