Points for Rebuttals and Letters of Support

Below is a list of points that X12 believes to be important and compelling but it is not a comprehensive list. We recognize that every health care industry stakeholder has a unique perspective and encourage organizations to customize their letters to reflect those perspectives. We also encourage the inclusion of detailed examples whenever possible.

1. We disagree with the NCVHS conclusions and the resulting recommendation.
2. X12's expectation is that trading partners will need to submit multiple versions of an implementation guide only during the transition period named in a Final Rule to advance the version of the standards. This is consistent with previous mandates.
3. Health care trading partners regularly exchange EDI messages based on different versions of the underlying EDI Standard successfully.
   • X12's other lines of business, including Finance, Material Management, Supply Chain, and Government, also routinely exchange different versions of different transactions.
4. The NCVHS' comments about backward compatibility indicate some level of misunderstanding of the term. Requiring backward compatibility stifles the inclusion of new and evolving business requirements in existing transactions.
5. The NCVHS may be using the term “backward compatibility” when they are speaking about cross-compatibility.
   • Cross-compatibility means that separate transactions in different versions interact smoothly and effectively.
6. X12's maintenance processes include verification that information can flow smoothly through the health care transaction workflows.
   • This is true for X12's previous maintenance process based on change requests (CRs) and Business Requirements/Technical Specifications (BRTS)
   • This is true for X12's current maintenance process based on maintenance requests (MRs) and Impact Assessments (IAs).
7. X12 can respond to concerns about cross-compatibility in its request for interpretation process (RFI) or via MRs applied to upcoming versions of the implementation guides.
8. X12's decision to move sets of transactions forward for consideration was based on several types of feedback.
   • NCVHS recommendations that the health care industry is better served by more frequent mandated upgrades with fewer revisions in each.
   • Industry feedback that trading partners are working simultaneously to satisfy several federal health care mandates and smaller sets of revisions are more manageable.
9. List benefits your organization will realize when newer versions of the transactions are mandated in as much detail as possible. You can use the list of benefits we included in our recommendation letter or you can personalize the benefits based on your organizations specific uses of the transactions.
10. The NCVHS wants actual cost-benefit information to move the implementation guides forward, however history, experience, and feedback from commenters indicate this is unrealistic as organizations don't invest the time and resources there is an NPRM or a Final Rule compelling implementation. Indicate when your organization is willing to incur costs that can be measured related to advancing the version of these implementation guides.
11. The NCVHS included a need for a timelier federal process to advance versions. X12 agrees with that in general, but disagrees strongly with a statement that we can't advance the version of mandated transactions until a long-standing federal process is changed. That's out of scope for moving a recommendation forward to the NPRM process.
12. The NCVHS indicated there was little industry support for advancing the version of these transactions. X12 strongly disagrees with that assessment based on the comments submitted and on the number of commenters compared to the number of implementers. We encourage organizations who didn't comment to use their voice to support a reconsideration of the NCVHS' initial recommendation based on the additional value implementers will realize from the additional functionality and clarified instructions.
13. It may also be valuable for industry stakeholders to indicate there is also a cost associated with not advancing the versions to better support new and emerging requirements.
14. X12's position is that much of the information the NCVHS is asking for and the concerns they note in their recommendation are more appropriately gathered from the impacted and materially interested health care EDI experts, both business and technical, who represent the health care industry implementers. Gathering feedback on benefits, concerns, implementation details, and other intangibles is one of the identified purposes of the Notice of Proposed Rulemaking (NPRM). 
15. Related to the NCVHS' concerns about impending changes to code lists including ICD-11 and NDC, it is not reasonable to hold up finished work based on an expectation of future requirements that are not fully developed and for which no implementation schedule exists.
16. Moving to an updated version of these transactions sets the industry up to react quickly to more frequent but smaller updates in the future.
17. It may be beneficial to state clearly that these transactions are broadly implemented in your organization and are a critical component of your effective claims processing systems.
18. X12 recognizes that we've “thought outside the box” by suggesting that the NCVHS recommend moving forward with the 008020 versions and using the NPRM process to ask the industry experts who work with these transactions daily to weigh in with whether 008020 or a later version should be named in a Final Rule. Based on the realities of the Federal Rulemaking Process timeline, this is the best way to ensure the Final Rule names the latest version available after consideration of the NPRM comments.