Medicare Fee-For-Service (FFS) Policy Regarding 90 Day Discretionary Enforcement Period for Non-Compliant HIPAA Covered Entities

The Centers for Medicare and Medicaid Services (CMS) announced it would not initiate enforcement action with respect to any HIPAA covered entity that is non-compliant with Version 5010, NCPDP, NCPDP D.0 and 3.0 standards until 90 days after the upcoming January 1, 2012 compliance date. Although compliance will not be enforced for Version 5010 until April 1, 2012, it is important to continue to take the necessary steps to complete your transition to Version 5010 as soon as possible.

What the 90 Day Discretionary Enforcement Period Means For Medicare Fee-For-Service

Medicare FFS has experienced significant increases in 5010 production transactions during the last few months. However, there are many submitters that have tested but not taken the step to move into production for 5010 and D.0. In addition, there are many submitters that have not yet initiated testing with their Medicare Administrative Contractor (MAC). Therefore, to ensure that submitters and receivers continue to make progress, Medicare FFS is planning to take the following steps for submitters and receivers of Medicare Part B and Durable Medical Equipment (DME) transactions:

  • In December 2011, submitters and receivers that have tested and been approved for 5010/D.0 will be notified that they have 30 days to cutover to the 5010/D.0 versions.
  • Submitters and receivers that have not yet tested will be notified in December 2011 that they must submit their transition plans and timelines to their MAC within 30 days.
  • MACs will notify the submitters and receivers, but submitters/receivers have the responsibility to notify the providers they service.

Note: Submitters and receivers of Medicare Part A transactions will follow the same action plan starting 30 days after Part B and DME.

Keep Up to Date on Version 5010 and ICD-10.

Please visit  the CMS ICD-10 website for the latest news and resources, and to download and share the implementation widget today!