Section title: News

X12 Responds to the NCVHS Recommendations to HHS

As you may recall, X12 recently issued a member notice related to the National Committee on Vital and Health Statistics (NCVHS) recommendation to the Secretary of Health and Human Services (HHS). The recommendation was that HHS not adopt the 008020 versions of X12’s claims and remittance advice implementation guides. We strongly disagree with the NCVHS’ recommendation and their rationale and the X12 officers, X12N officers, other subject matter experts, and staff went right to work on a response to the recommendation.

In line with our commitment to inform our member representatives about important matters timely, we wanted to let you know X12’s response asking that NCVHS reconsider their recommendation has been finalized and will be delivered shortly. Once the response is delivered, it will be posted here.

In our previous communication, we asked the X12N constituents to encourage their organizations to submit letters of support for advancing the version on these mandated standards so industry stakeholders can utilize the functional enhancements and improvements to the instructions in the implementation guides. The NCVHS also called for stakeholders to submit benefit and return on investment data to assist in the review of future proposals, noting that this is not limited to financial benefits and returns.

To assist X12 members with these letters of support, we have prepared two informative write-ups. 

  • A list of the points included in our initial recommendation or in this response to the NCVHS, available here.
  • A list of individuals who received a copy of our response to NCVHS, available here.

If you have questions about the informative write-ups, please use the X12 Feedback form to let us know and we will respond as quickly as possible.

We are also soliciting letters of support from implementers and other stakeholders that don’t typically participate in X12’s collaborations or provide input when NCVHS issues a call for comments. If you have suggestions for organizations that may want to weigh in, feel free to contact them yourself or to use the X12 Feedback form to share the organization’s name and the contact person’s email address so we can reach out to them.

As we said in our initial message, we recognize that you have invested a lot of hard work and dedicated effort over many years to enhance and refine these implementation guides to meet evolving industry needs. We appreciate your commitment and effort and 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.

Finally, we ask that each X12N constituent to encourage their member organization to prepare a letter in support of the implementation guides in our second recommendation to the NCVHS. These letters of support can be sent to X12 now for inclusion in our testimony to the NCVHS when they hold a hearing on these recommendations. If your organization prefers to send its letter of support directly to the NCVHS, you should watch for the NCVHS call for comments on the second recommendations. We will also send a notice when the NCVHS call for comments is issued. The second set of recommendations includes the following implementation guides.

  • 008030X329 Health Care Claim Status Request and Response (276/277)
  • 008030X333 Benefit Enrollment and Maintenance (834)
  • 008030X334 Payroll Deducted and Other Group Premium Payment for Insurance Products (820) 

Thank you in advance for working to ensure that NCVHS hears from a wide variety of stakeholders and implementers who support X12’s request that they reconsider their recommendation and move our implementation guides forward into the Rulemaking process.



Cathy Sheppard