NCVHS Decision on X12 HIPAA Recommendations
The National Committee on Vital and Health Statistics (NCVHS) conducted a full committee meeting on Wednesday, June 14, 2023 to review, discuss, and ultimately vote on a recommendation to the Secretary of Health and Human Services (HHS) regarding X12’s proposal to update its already-mandated claims and remittance transactions from the 005010 to 008020 version.
NCVHS voted to recommend that HHS not adopt the 008020 version at this time, then explained:
“NCVHS acknowledges the obsolescence of version 005010 and the need to move to an updated version of the X12 standard; however, concerns over accommodating multiple versions across transactions, accommodating changes in code sets and the long lead-time for regulatory processes need to be addressed. The Committee urges X12, in conjunction with industry and regulators, to speedily address the needs and submit a new version for adoption under HIPAA.
The Committee commends X12 and the participating stakeholders in its proof of concept (POC) and looks forward to the results that may shed more light on backward and cross standard compatibility. In addition, the POC could provide supplemental value data to support X12’s future proposal to move the next version of these standards forward.
The Committee encourages stakeholders to submit benefit and return on investment data either to NCVHS or CMS upon request to assist in the review of all future proposals.”
X12 leaders were surprised to hear this recommendation and we strongly disagree with NCVHS’ recommendation and their rationale. We recognize that you have invested a lot of hard work and dedicated effort over many years to enhance and refine the recommended versions of these transactions to meet industry needs. We remain committed to forging a path forward for these claims and remittance transactions, the rest of our currently mandated transactions, and the new transactions X12 intends to propose for mandate. To that end, the X12 officers, X12N officers, other subject matter experts, and staff are working on several initiatives to address NCVHS’ recommendations and their concerns.
Reasons provided by NCVHS include:
- Concerns regarding cross-version compatibility between different transactions
- Not enough information regarding the value of the enhancements to the health care industry
- Lack of support for two impending, but not yet fully defined updates, ICD-11 and NDC formatting
Over the past few months, X12 leaders met with NCVHS representatives to address their concerns regarding cross-version compatibility. The PoC pilot participants are actively testing the claims and remittance transactions with related transactions, such as acknowledgments, and no version compatibility issues have been identified.
In our recommendation to NCVHS on this series of transactions, we provided estimates about the level of effort and extrapolated costs for implementing these transactions. Early feedback from the PoC indicates our estimates may have been high, which we believe is good. We also laid out the enhancements and expected benefits of moving to these later versions for these transactions.
Domestically, ICD-11 is still being studied by the Federal Government. X12 remains ready, willing, and able to accommodate this once the industry requirements have been clarified. Additionally, the FDA has published a proposed rule to modify the format of the NDC, and once a final rule is published, X12 will accommodate the requirements.
We appreciate your support as we work to ensure our enhanced implementation guides can move forward and into the NPRM process where industry experts, rather than a public advisory body, can speak to the benefits of implementing these enhanced implementation instructions and air any concerns related to doing so.
We encourage each member representative to ask their organization to submit letters documenting support for moving these enhanced claims and remittance implementation guides to the Department of Health and Human Services (HHS) and/or the Centers for Medicare and Medicaid Services (CMS). We will follow up with contact information and such in the coming days. We also encourage each member representative to proactively encourage their organizations to prepare letters of support for the other implementation guides that X12 intends to put forward.
We will communicate with you, our member representatives, regarding this situation regularly as it evolves.