Testimony Before
National Committee on Vital and Health Statistics
Standards and Security Subcommittee
5010 Implementation Requirement
Presented By:
Bing Herald
Immediate Past President
July 31, 2007
Washington, DC
Healthcare Billing and Management Association
1540 South Coast Highway, Suite 203
Laguna Beach, CA 92651
MR. CHAIRMAN AND MEMBERS OF THE NATIONAL COMMITTEE ON VITAL AND HEALTH STATISTICS (NCVHS) STANDARDS AND SECURITY SUBCOMMITTEE. I AM BING HERALD, IMMEDIATE PAST PRESIDENT OF THE HEALTHCARE BILLING AND MANAGEMENT ASSOCIATION – HBMA. ON BEHALF OF HBMA AND THE MORE THAN 600 COMPANIES THAT BELONG TO OUR ASSOCIATION, I WANT TO THANK YOU FOR THIS OPPORTUNITY TO PRESENT OUR VIEWS ON THE PROPOSED MOVE TO THE 5010 STANDARDS FOR ELECTRONIC CLAIMS TRANSACTIONS.
IN ADDITION TO MY RESPONSIBILITIES AS IMMEDIATE PAST-PRESIDENT OF HBMA, I AM ALSO THE PRESIDENT OF MEDICAL BUSINESS SERVICE (MBS) A LARGE MEDICAL BILLING COMPANY BASED OUT OF CORAL GABLES, FLORIDA. MBS IS ONE OF THE LARGEST PRIVATELY OWNED BILLING SERVICES FOR HOSPITAL-BASED PHYSICIANS. WE HANDLE MEDICAL BILLING AND PRACTICE MANAGEMENT FOR DOZENS OF LARGE PHYSICIAN PRACTICES LOCATED THROUGHOUT THE EASTERN UNITED STATES.
WITH ME TODAY IS MR. RICHARD USRY. RICHARD IS THE SENIOR VP AND CHIEF TECHNOLOGY OFFICER OF ARBORMED CORPORATION, A MULTI-STATE BILLING AND MANAGEMENT COMPANY. ARBORMED OPERATES IN 39 STATES. THEY WORK DIRECTLY WITH ALL MEDICARE, MEDICAID AND BC/BS PLANS IN THESE STATES FOR ALL ANSI 4010A1 CLAIMS PROCESSING AS WELL AS INTERFACE WITH OVER 10 MAJOR CLAIMS CLEARING HOUSES.
RICHARD HAS BEEN DESIGNING, INSTALLING AND IMPLEMENTING BILLING SYSTEMS FOR OVER 35 YEARS. HE ALSO DESIGNED ONE OF THE FIRST ELECTRONIC CLAIMS TRANSMISSION SYSTEMS WITH BLUE CROSS BLUE SHIELD OF FLORIDA IN THE EARLY 70S. I’VE ASKED RICHARD TO BE HERE THIS MORNING TO ASSIST WITH ANY TECHNICAL QUESTIONS THAT MAY BE BEYOND MY PAY GRADE.
MR. CHAIRMAN, HBMA IS THE ONLY TRADE ASSOCIATION REPRESENTING THIRD-PARTY MEDICAL BILLING COMPANIES.
HBMA MEMBERS PROCESS MEDICAL BILLING AND OTHER CLAIMS PROCESSING SERVICES INTEGRAL TO THE HEALTHCARE DELIVERY SYSTEM. BASED UPON RECENT MEMBER SURVEYS, WE ESTIMATE THAT HBMA MEMBER COMPANIES SUBMIT MORE THAN 100 MILLION CLAIMS A YEAR FOR REVENUES EXCEEDING $15 BILLION PER YEAR.
ALTHOUGH A LARGE PERCENTAGE OF BILLING COMPANIES WORK FOR THE HOSPITAL BASED SPECIALTIES – EMERGENCY MEDICINE, PATHOLOGY, ANESTHESIOLOGY, AND RADIOLOGY, BILLING COMPANIES CAN BE FOUND WORKING FOR PHYSICIANS IN VIRTUALLY EVERY SPECIALTY. MY COMPANY IS TYPICAL OF MANY HBMA MEMBERS IN THAT OUR CORE BUSINESS SPECIALTY IS RADIOLOGY BILLING BUT WE ALSO HANDLE BILLING FOR OTHER SPECIALTIES, INCLUDING, PATHOLOGY, RADIATION ONCOLOGY, AND CARDIOLOGY.
IN PREPARING FOR TODAY’S TESTIMONY, WE WERE ASKED TO FOCUS ON THREE CORE QUESTIONS RELATED TO THE MOVE TO THE 5010 STANDARDS:
- WORKFLOW
- TRAINING
- SYSTEMS CHANGES
BEFORE GETTING INTO THE SPECIFICS OF OUR TESTIMONY, I DO WANT TO SAY AT THE OUTSET THAT HBMA HAS BEEN STRONG SUPPORTER OF THE MOVE TO ELECTRONIC TRANSACTIONS IN THE HEALTHCARE ENVIRONMENT. WE SUPPORTED THE ORIGINAL HIPAA LEGISLATION; WE HAVE WORKED WITH THIRD PARTY PAYERS – GOVERNMENT AND COMMERCIAL – TO DEVELOP A WORKABLE SYSTEM. LIKE SO MANY OTHERS, WE ARE FRUSTRATED BY THE LACK OF PROGRESS.
BILLING COMPANIES FIND IT IRONIC THAT NEARLY EVERY ASPECT OF OUR BUSINESS CAN BE HANDLED ELECTRONICALLY. WHEN MY COMPANY NEEDS TO ORDER SUPPLIES, WE CAN ORDER THEM AND PAY FOR THEM ELECTRONICALLY. IN ADDITION WE CAN TRACK EVERY MOVEMENT OF OUR SHIPMENTS ELECTRONICALLY. I CAN BILL MY CLIENT PHYSICIANS ELECTRONICALLY AND THEY CAN PAY ME ELECTRONICALLY. I HANDLE PAYROLL ELECTRONICALLY SO THAT ALL OF MY EMPLOYEES HAVE THEIR PAYCHECKS DEPOSITED ELECTRONICALLY. THE FEDERAL GOVERNMENT ALLOWS ME TO PAY MY TAXES AND SUBMIT MY RETURN ELECTRONICALLY.
VIRTUALLY THE ONLY AREA WE CANNOT CONDUCT SEAMLESS, EFFICIENT ELECTRONIC TRANSACTIONS IS OUR CORE BUSINESS FUNCTION – MEDICAL BILLING. AS WE HAVE IN THE PAST, WE MUST ONCE AGAIN ASK WHY? WHY HAS IT TAKEN MORE THAN 10 YEARS TO DEVELOP THE INFRASTRUCTURE NECESSARY TO MOVE MEDICINE INTO THE 20TH CENTURY – LET ALONE THE 21ST.
WHEN THE 4010 STANDARDS WERE ANNOUNCED SEVERAL YEARS AGO, THEY WERE INITIALLY GREETED BY THE INDUSTRY WITH GREAT FANFARE. FINALLY, WE WOULD BE CREATING A UNIFORM PLATFORM FOR HEALTH CARE CLAIMS (837), HEALTHCARE CLAIM PAYMENT (EOB/ERA- 835), HEALTH CARE CLAIM STATUS (276/277), AND HEALTH CARE CLAIM SERVICE REVIEW (278), THESE VISIONARY STANDARDS WOULD ELIMINATE THE NUMEROUS CLAIM FORMS OF THE INDIVIDUAL THIRD PARTY PAYERS. GONE WOULD BE THE NSF (NATIONAL SIMILAR FORMAT) OF WAYS PAYERS ASKED FOR INFORMATION AND TRANSMITTED REMITTANCE ADVICE TO PHYSICIANS.
UNFORTUNATELY, OUR EUPHORIA OVER THE ADOPTION OF THE 4010 STANDARDS WAS SHORT-LIVED AS A NEW TERM ENTERED THE MEDICAL BILLING LEXICON – COMPANION GUIDES. SOON, EVERY THIRD PARTY PAYER – INCLUDING MEDICARE – ANNOUNCED THE DEVELOPMENT OF COMPANION GUIDES TO ACOMPANY THE 837 4010A1. THE DIFFERENT WAYS THIRD PARTY PAYERS WANTED YOU TO ORGANIZE THE INFORMATION ON THE 835 WERE AS NUMEROUS AS THERE WERE COMPANIES. FOR EXAMPLE THE 4010A1 SET THE STANDARD OF 50 LINE ITEMS PER CLAIM BUT A COMPANION GUIDE WOUL LIMIT YOU TO ONLY 6 LINE ITEMS PER CLAIMS.
AT ONE POINT, IT WAS ESTIMATED THAT THERE WERE MORE THAN 1,200 COMPANION GUIDES PUBLISHED BY THE VARIOUS THIRD PARTY PAYERS. AS YOGI BERRA WOULD SAY, IT WAS DÉJÀ VU ALL OVER AGAIN.
HERE ARE SOME EXAMPLES OF THE INTRODUCTIONS TO COMPANION GUIDES THAT WERE ISSUED WITHIN DAYS OF THE EFFECTIVE DATE FOR USE OF THE 837 4010A1:
Government Payer
To properly process 837 transactions, XX-XXX requires only ONE transaction type in each transmission file beginning with the ISA and ending with the ISE envelope segments. For example if the submitter sends Chargeable/FFS 837 transaction data for Professional, Dental and Institutional, there would be a separate file for each transaction (e.g. One containing only the 837P professional data, one containing only 837I institutional data and one file containing only 837D dental data.).
Every effort has been made to prevent errors in this document. However, if there is a discrepancy
Between this document and the Implementation Guide, the Implementation Guide is the final authority.
Government Payer
This Companion Guide is intended for trading partner use in conjunction with the ANSI ASC X12N National Implementation Guide. This document is provided to further define situational components of the transaction and specifies data clarification where applicable.
Commercial Insurer
This companion guide is intended only to assist submitters with information that must be supplied to XXX XXXXX XXXXX in the Professional Health Care Claim transaction (837). ThisDocument is not an implementation guide. This guide only addresses information fields that:
- consist of information we are required to or allowed to supply you
- are identified as mutually defined
- are defined by the payer
Submitters must use the National Electronic Data Interchange Transaction Set Implementation Guide for the Professional Health Care Claim transaction (837) for complete instructions on submitting this transaction. This companion guide does not modify any of the requirements of the Implementation Guide. Transactions must include all the information identified in the Implementation Guide as required information.
SO AS WE LOOK AT MOVING TOWARDS ADOPTION OF THE 5010 STANDARDS, THE FIRST AND OVERWHELMING QUESTION WE ARE ASKED BY OUR MEMBERS IS: “WILL THIS ELIMINATE THE NEED FOR COMPANION GUIDES?” UNFORTUNATELY, OUR ASSESSMENT THUS FAR LEADS US TO CONCLUDE THAT WHILE THE 5010 STANDARDS WILL ELIMINATE THE NECESSITY FOR MANY COMPANION GUIDES, IT NEITHER PRECLUDES PAYERS FROM ISSUING NEW COMPANION GUIDES NOR DOES IT ELIMINATE THE NEED FOR SOME PLANS TO CONTINUE TO HAVE COMPANION GUIDES. THIS CONCLUSION IS IMPORTANT BECAUSE IT LEADS DIRECTLY TO THE QUESTIONS YOU HAVE ASKED US TO ADDRESS.
1. SYSTEM CHANGES
AS I JUST NOTED, THE 4010A1 STANDARDS WERE ALMOST IMMEDIATELY ACCOMPANIED BY THE ISSUANCE OF COMPANION GUIDES BY THIRD PARTY PAYERS. SINCE 4010A1 BECAME MANDATORY IN 2003, BILLING COMPANIES, MEDICAL SOFTWARE COMPANIES, AND THE CLEARINGHOUSE INDUSTRY HAVE ALL WORKED HARD TO DEVELOP SOFTWARE AND PROCESSES THAT WOULD TAKE STANDARD INFORMATION AND PROPERLY FORMAT THAT INFORMATION FOR THE SPECIFIC DEMANDS OF INDIVIDUAL PAYERS. BASICALLY, WE HAVE DEVELOPED PATCHES IN THE SYSTEM TO ACCOMMODATE THE VARIOUS 4010A1 COMPANION GUIDES IN ORDER TO “MAKE IT WORK”.
I’M SURE ALL OF THE MEMBERS OF THIS SUBCOMMITTEE ARE FAMILIAR WITH THE OLD SAW – “IF IT AIN’T BROKE, DON’T FIX IT”? WHILE THE SYSTEM WAS BROKEN WHEN 4010 FIRST CAME OUT, WE’VE LARGELY FIXED THE PROBLEMS IT CREATED. BILLING COMPANIES, SOFTWARE VENDORS AND CLEARINGHOUSES HAVE SPENT MILLIONS OF DOLLARS TO TRY TO ACHIEVE SOME OF THE EFFICIENCIES WE WERE PROMISED BY HIPAA. THE PATCHES ARE WORKING, OUR STAFFS HAVE LEARNED THE NUANCES OF INDIVIDUAL COMPANIES AND, FROM AN ELECTRONIC STANDPOINT, THE SYSTEM IS FUNCTIONING.
THERE IS NO QUESTION ADOPTION OF THE 5010 STANDARDS WILL RESULT IN SYSTEM CHANGES.
IN ALL LIKELIHOOD, THE ELECTRONIC PATCHES AND “WORK AROUNDS” WE’VE PUT IN PLACE WILL NOT WORK WITH THE NEW STANDARDS AND MAY CAUSE SYSTEMS TO CRASH. BILLING COMPANIES AND PHYSICIANS WILL INCUR COSTS FOR THESE SYSTEM CHANGES – BOTH DIRECT AND INDIRECT.
DIRECT – THE COST OF PURCHASING THE SOFTWARE NECESSARY TO MEET THE 5010 FORMAT STANDARDS. WE DO NOT HAVE ANY FIRM PRICING DATA AT THIS TIME; HOWEVER, BASED UPON PRELIMINARY DISCUSSIONS WITH SOME SOFTWARE VENDORS, WE BELIEVE THE SOFTWARE DEVELOPMENT COSTS COULD BE MINIMAL TO PHYSICIANS OR BILLING COMPANIES. THESE SAME SOFTWARE VENDORS TELL US THAT THEIR COSTS WILL BE SIGNIFICANT BUT THEY WILL LIKELY HAVE TO ABSORB THESE COSTS AS AN EXPENSE OF DOING BUSINESS. SO WHILE THERE WILL LIKELY BE SOME DIRECT COSTS, WE DO NOT BELIEVE THEY WILL BE SIGNIFICANT.
INDIRECT – THERE WILL BE GLITCHES IN THE SYSTEM. IN THE MORE THAN 30 YEARS I’VE BEEN WORKING IN MEDICAL BILLING, I HAVE YET TO SEE A SOFTWARE OR SYSTEM CHANGE THAT HAS GONE OVER WITHOUT A HITCH. PROBLEMS ARE INEVITABLE AND THIS MEANS ADDED COSTS ARE INEVITABLE. AS A BUSINESS, YOU HOPE TO KEEP THOSE COSTS TO A MINIMUM BUT YOU HAVE TO PRESUME THERE WILL BE SOME COST INVOLVED IN A SYSTEM CHANGE.
WHEN I AS A BUSINESSMAN CONSIDER A SYSTEM CHANGE, I LOOK AT WHAT I CAN EXPECT AS A RETURN ON MY INVESTMENT? WILL THIS CHANGE MAKE ME MORE EFFICIENT? WILL THIS REDUCE MY OVERHEAD? WILL THIS MAKE MY STAFF MORE PRODUCTIVE? I MENTIONED EARLIER THAT VIRTUALLY EVERY OTHER TYPE OF ELECTRONIC BUSINESS TRANSACTION I CONDUCT CAN BE DONE EFFICIENTLY AND RESULTS IN LOWER COSTS FOR MY COMPANY. LESS PAPER, FEWER MISTAKES, TIMELIER FILING, ETC. I DIDN’T DO THESE THINGS BECAUSE THE GOVERNMENT TOLD ME TO DO THEM; I DID THEM BECAUSE THEY MADE BUSINESS SENSE.
EQUALLY IMPORTANT, THE VENDORS WITH WHOM I DO BUSINESS HAVE A FINANCIAL INCENTIVE TO MAKE THE CHANGEOVER GO SMOOTHLY AND EFFICIENTLY AND RESULT IN A SAVINGS TO ME. IN HEALTHCARE, THERE HAS LONG BEEN THE SUSPICION THAT WHILE PHYSICIANS AND HOSPITALS WANT MORE EFFICIENT TRANSACTIONS AND BILLING COMPANIES AND SOFTWARE VENDORS WANT MORE EFFICIENT TRANSACTIONS AND CLEARINGHOUSES WANT MORE EFFICIENT TRANSACTIONS, THIRD PARTY PAYERS – WHETHER GOVERNMENT OR COMMERCIAL – HAVE LITTLE INCENTIVE TO MAKE THE SYSTEM WORK SMOOTHLY. I KNOW THAT MANY THIRD-PARTY PAYERS DISPUTE THIS OPINION BUT ONE HAS TO WONDER WHY IT IS HAS TAKEN SO LONG TO GET THE SYSTEM WORKED OUT?
NOW YOU ASK US TO REACT TO NEW STANDARDS WHICH, WE BELIEVE, WILL SERIOUSLY DISRUPT OUR BUSINESS OPERATIONS, WITH LITTLE OR NO IMPROVEMENT IN EFFICIENCY TO SHOW FOR THIS INVESTMENT.
SO TO THE QUESTION, WILL ADOPTION OF THE 5010 STANDARDS FORCE ME AND OTHER BILLING COMPANIES TO MAKE SYSTEM CHANGES, THE ANSWER IS YES. AND THESE SYSTEM CHANGES WILL COST MONEY.
2, TRAINING
THE SUBCOMMITTEE ASKED US TO ALSO ADDRESS THE ISSUE OF TRAINING. BILLING COMPANIES SPEND A CONSIDERABLE AMOUNT OF MONEY ON EMPLOYEE TRAINING. THIS IS DUE TO THE CONSTANTLY CHANGING NATURE OF THE BUSINESS, AS WELL AS EMPLOYEE TURNOVER.
BILLING COMPANIES WILL HAVE TO RETRAIN EMPLOYEES ON THE NEW SOFTWARE TO BE COMPLIANT WITH THE 5010 STANDARDS.
3. WORKFLOW
WITH THE PATCHES AND WORK-AROUNDS WE HAVE INSTITUTED IN OUR BUSINESS, WE HAVE MADE THE SYSTEM WORK. IN SOME CASES IT IS WITH THE PROVERBIAL BUBBLE GUM AND BAILING WIRE, BUT IT IS WORKING. WE ARE ABLE TO SUBMIT CLAIMS IN A TIMELY FASHION, GET PAID ON THOSE CLAIMS IN A TIMELY FASHION, AND DO THIS AT A REASONABLE COST TO THE SYSTEM.
AS WE LOOK DOWN THE ROAD TO IMPLEMENTATION OF 5010, WE SEE SERIOUS DISRUPTIONS IN OUR WORKFLOW. ALTHOUGH I WILL NOT ELABORATE ON THIS POINT IN OUR TESTIMONY, I THINK IT MUST BE NOTED THAT SOME MEDICAL BILLING SOFTWARE VENDORS CURRENTLY SUPPORTING BILLING COMPANIES AND PHYSICIAN’S OFFICES WILL CHOOSE TO GET OUT OF THE MEDICAL BILLING SOFTWARE BUSINESS AS A RESULT OF THE ADOPTION OF THE 5010 STANDARDS. THIS WILL CAUSE WORKFLOW DISRUPTION.
AS A BILLING COMPANY, WE BELIEVE THAT FOR SOME PERIOD OF TIME, TRANSITION TO THE 5010 WILL CAUSE WORFLOW DISRUPTION. BILLING STAFF WILL BE POPULATING FIELDS NOT PREVIOUSLY CAPTURED ON THE CLAIM FORM WHICH WILL DECREASE STAFF PRODUCTIVITY. NEW INFORMATION WILL HAVE TO BE CAPTURED ON THE CLAIM FORMS WHICH WILL ALSO REDUCE MY EMPLOYEE’S PRODUCTIVITY.
WE ARE OFTEN RELIANT UPON OTHERS TO PROVIDE US WITH THE INFORMATION THAT GETS POPULATED INTO THE CLAIM FORM. WITH ADDITIONAL FIELDS TO COMPLETE, MY STAFF WILL NEED TO ASK FOR ADDITIONAL INFORMATION. IF PAST IS PROLOGUE, COLLECTING THAT INFORMATION WILL TAKE TIME AND CAUSE DELAYS IN THE SUBMISSION OF A CLAIM.
IF, AS THE 5010 FIELDS SUGGEST, CMS WILL BE REQUIRING MORE INFORMATION FOR CLAIM PAYMENT, CMS MUST ENFORCE “CHAIN OF DATA” POPULATION OF THE FIELDS. FOR EXAMPLE, IT IS NOT UNCOMMON FOR A HOSPITAL TO COLLECT THE ADMIT DATA BUT FAIL TO PROVIDE THAT DATA TO THE RADIOLOGIST. THE RADIOLOGIST HAS NO ACCESS TO THIS DATA, THEIR CLAIM IS DENIED, AND THE HOSPITAL IS NOT HELD ACCOUNTABLE FOR PROVISION OF THE REQUIRED DATA. CMS NEEDS TO TAKE A STRONGER STANCE THAN MERELY RECOMMENDING THAT HOSPITALS OR REFERRING PHYSICIANS “PLAY FAIRLY”, THEY MUST ENFORCE THE TRANSACTION SET REQUIREMENTS.
IN ADDITION, WE ANTICIPATE SERIOUS PROBLEMS GETTING PAID IN A TIMELY FASHION. LEST YOU THINK OUR FEARS ABOUT THE IMPACT OF CHANGE ON OUR WORKFLOW, ONE NEED LOOK NO FURTHER THAN THE RECENT CMS CHANGEOVER TO THE PECOS – PROVIDER ENROLLMENT, CHAIN AND OWNERSHIP SYSTEM.
BEGINNING OCTOBER 6, 2003 PECOS WAS USED TO COLLECT AND MAINTAIN THE DATA SUBMITTED ON FORM CMS-855 ENROLLMENT APPLICATION. THIS EFFECTIVELY CREATED A NATIONAL ENROLLMENT SYSTEM FOR MEDICARE. PROGRAM TRANSMITTALS WERE DISTRIBUTED WITH THE VARIOUS POLICIES AND PROCEDURES TO BE USED BY PART B CARRIERS IN COORDINATING THE ENROLLMENT OF PHYSICIANS.
THE ROLLOUT OF THIS NEW SYSTEM, THAT WAS SUPPOSED TO BE SO EFFICIENT, WAS SO MESSED UP THAT THOUSANDS OF PHYSICIANS EXPERIENCED ENROLLMENT DELAYS LASTING 6 – 10 MONTHS WITH SOME TAKING A YEAR TO GET STRAIGHTENED OUT! DURING ALL THIS TIME, PHYSICIANS WERE WORKING FOR FREE AND THEY WERE NEVER MADE WHOLE. THEY NEVER RECEIVED ANY INTEREST PAYMENTS FOR DELAYED PAYMENTS. SOME YOUNG PHYSICIANS ALMOST WENT BANKRUPT RIGHT OUT OF THE STARTING GATE. OR, MORE RECENTLY, LOOK HOW LONG IT TOOK HHS/CMS TO ISSUE THE DISSEMINATION NOTICE THAT WAS ESSENTIAL TO IMPLEMENTATION OF THE NPI? FOR OVER A YEAR WE WERE TOLD BY THE DEPARTMENT THAT THE ISSUANCE WOULD BE “SOON” THEN “VERY SOON” THEN “IMMINENT”. IN THE END, THE NOTICE WAS ISSUED ONLY DAYS BEFORE THE EFFECTIVE DATE OF THE NPI.
IMPLEMENTATION
MR. CHAIRMAN, BILLING COMPANIES AND PHYSICIANS WILL BE ASKED TO INVEST THOUSANDS OF DOLLARS AND HUNDREDS OF PERSON-HOURS INTO A SYSTEM THAT WILL SLOW DOWN PAYMENTS AND COMPLICATE THE SYSTEM. AND AGAIN, WE MUST ASK – FOR WHAT?
AS BILLING COMPANIES, WE ARE ONE LINK IN THE CLAIMS PAYMENT CHAIN. WE WILL COMPLY WITH WHATEVER STANDARDS AND REQUIREMENTS THE GOVERNMENT MAY IMPOSE. BUT WE IMPLORE YOU TO MAKE RECOMMENDATIONS THAT DEMONSTRATE THAT WE HAVE LEARNED FROM PAST MISTAKES.
THE ROLLOUT OF THESE CHANGES, IN WHICH NUMEROUS ENTITIES ARE INVOLVED, SHOULD BE STRUCTURED AS A RELAY, NOT AS A COMMON SPRINT TO THE FINISH LINE. WITH NPI, WHAT SHOULD HAVE BEEN A RELAY, WAS A SPRINT TO A COMMON FINISH LINE FOR EVERYONE INVOLVED. THE EVIDENCE OF THE FOLLY OF THIS APPROACH IS SEEN BY REPORTS THAT UPWARDS OF 90% OF PHYSICIANS HAVE THEIR NPI BUT FEWER THAN 40% OF CLAIMS ARE BEING PROCESSED USING THE NPI.
FOR THE 5010, WE RECOMMEND THE ROLLOUT BE STRUCTURED WITH HEALTH PLANS BEING REQUIRED TO ADOPT THE 5010 STANDARDS BY A TIME CERTAIN. PRIOR TO MOVING TO THE NEXT PHASE IN THE ROLLOUT, THERE SHOULD BE ADEQUATE TESTING AS PART OF THE DEMONSTRATION BY THAT PARTICULAR ENTITY THAT IT IS COMPLIANT. ONCE THE HEALTH PLANS HAVE COMPLETED TESTING AND DEMONSTRATED COMPLIANCE, THEN CLEARINGHOUSES SHOULD BE REQUIRED TO ADOPT THE 5010 STANDARDS BY A SECOND TIME CERTAIN. AGAIN, THERE SHOULD BE PILOT TESTING AS PART OF THIS PROCESS.
FINALLY, ONCE CLEARINGHOUSES AND HEALTH PLANS HAVE DEMONSTRATED COMPLIANCE, THEN PROVIDERS (INCLUDING THEIR BUSINESS PARTNERS) SHOULD BE GIVEN A TIME-CERTAIN DEADLINE FOR INCORPORATION OF THE 5010 STANDARDS IN THEIR OPERATIONS. AGAIN, PILOT TESTING SHOULD BE BUILT INTO THIS PROCESS BEFORE MOVING TO FINALIZATION OF THE PROCESS.
BY SEQUENCING THE ROLLOUT AND INCORPORATING PILOT TESTING AT EACH PHASE, WE WILL MINIMIZE DISRUPTION AND THE LIKELIHOOD THAT THERE WILL BE SIGNIFICANT DELAYS IN CLAIMS PAYMENT.
THE REALITY IS, MR. CHAIRMAN, THAT THERE ARE STILL OTHER “INTERIM” STEPS THAT WILL HAVE TO BE TAKEN BEFORE WE REACH OUR DESIRED GOAL OF AN EFFICIENT, FULLY AUTOMATED CLAIMS AND PAYMENT SYSTEM. ADOPTION OF THE 5010 IS A STOPPING POINT ALONG THE WAY BUT IT IS A STOPPING PIONT THAT FRANKLY IS UNNECESSARY. THERE’S NOTHING IN 5010 THAT’S GOING TO MAKE MY LIFE OR THE LIFE OF MY PHYSICIAN CLIENTS, EASIER. WHAT IN 5010 WILL MAKE MY BUSINESS MORE EFFICIENT? WHAT IN 5010 WILL ALLOW ME TO REDUCE MY COST OR MY OVERHEAD? IT IS A TRANSITIONAL SET OF STANDARDS THAT WILL STILL HAVE TO BE REPLACED BY FUTURE ITERATIONS? SO WE IN THE BILLING COMMUNITY ASK WHY?
WE BESEECH YOU TO GET IT ALL WORKED OUT, AND THEN BRING US THE FINAL – FINAL PRODUCT. LET US MAKE ONE CHANGE THAT MOVES US TO THE NEXT – AND FINAL – LEVEL. DON’T ASK US TO INCUR UNRECOVERABLE COSTS THAT ONLY SOLVE PART OF THE PROBLEM.
ADOPTING 5010 WON’T GET US TO THE FINISH LINE ANY FASTER, IT WON’T ACCELERATE ANY SAVINGS PROVIDERS MIGHT REALIZE AS A RESULT OF IMPROVED EFFICIENCIES. ADOPTING 5010 WILL RAISE COSTS, SLOW DOWN WORKFLOW AND MAKE IT MORE COSTLY FOR HEALTHCARE TO BE DELIVERED. PLEASE DO NOT ALLOW EVERYONE TO KEEP DROPPING THE BATON.
AFTER 2+ YEARS OF PHYSICIAN PAY FREEZES AND REDUCTIONS, NOW IS NOT THE TIME TO ASK PHYSICIANS TO INCUR NEW COSTS WITH LITTLE CHANCE OF SEEING ANY RETURN ON THAT INVESTMENT.
ON BEHALF OF THE BILLING COMMUNITY, WE APPRECIATE THIS OPPORTUNITY TO TESTIFY TODAY.
I’M HAPPY TO ANSWER ANY QUESTIONS YOU MAY HAVE.