1405 S Fern St #92957 ● Arlington VA 22202 ● Phone (703) 970-4480 ● Fax (703) 970-4488 ● X12.org
December 19, 2025
Executive Secretary
National Committee on Vital and Health Statistics
Good day,
I am writing today on behalf of X12, a standards development organization (SDO) accredited by the American National Standards Institute (ANSI). Via this letter, X12 respectfully recommends advancing the version of its already mandated health care transactions.
X12 recommends that each mandated transaction be advanced to version 008060, the latest published version. The list below reflects the individual recommendations.
- 008060X322 Health Care Claim Payment/Advice (835)
- 008060X323 Health Care Claim: Professional (837)
- 008060X324 Health Care Claim: Institutional (837)
- 008060X325 Health Care Claim: Dental (837)
- 008060X329 Health Care Claim Status Request and Response (276/277)
- 008060X332 Health Care Eligibility/Benefit Inquiry and Information Response (270/271)
- 008060X333 Benefit Enrollment and Maintenance (834)
- 008060X334 Payroll Deducted and Other Group Premium Payment for Insurance Products (820)
- 008060X342 Health Care Services Review – Request for Review and Response (278)
- 008060X340 Health Care Claim Request for Additional Information (277)
- 008060X341 Additional Information to Support a Health Care Claim or Encounter (275)
- 008060X343 Additional Information to Support a Health Care Services Review (275)
As you know, X12 established and continues to focus on pilot testing that demonstrates the viability of the recommended transactions. This testing focuses on real-world exchanges conducted by expert X12 implementers committed to ensuring new features and functions perform as expected with no unintended negative impact. Moving forward, the library of scripts and expected results developed as part of the pilot will be pivotal in helping implementers verify their compliance.
Each of the X12 implementation guides included in this recommendation has a corresponding derived schema definition that supports the direct representation of the transaction in XML syntax. X12 mechanically produces these representations from the same metadata used to produce the implementation guide, ensuring there are no discrepancies between the syntaxes. X12 recommends naming both the 008060 EDI Standard representation (the implementation guide) and the associated XML representation as permitted syntaxes.
At a high level, each version of an X12 implementation guide builds on the previous version, adding enhancements and refinements to support new business processes, improve the exchange of data messages, increase consistency, and reduce costs across the health care industry. We understand that implementers need more details about specific enhancements and that they use that information in distinct ways, depending on their organization's policies and processes. It is also vital for implementers to evaluate enhancements and revisions in the context of related and complementary information in the transaction, and through the lens of their organization's proprietary software solutions. Revision reporting is not a one-size-fits-all activity.
Starting next week and continuing into the beginning of 2026, X12 will provide several change summary options, including:
- A mechanical comparison, posted on our website, that includes all changes between a 005010 implementation guide and its 008060 counterpart.
- A list, posted on our website, of high-value revisions calling out particular enhancements and why they are valuable to the health care industry stakeholders, including consumers.
- A markup posted on our website of the transaction set listing for each implementation guide, identifying segments that were revised, so implementers have a starting point for their analysis.
- A summary of the mandated Operating Rules published by CAQH CORE that were integrated into the corresponding 008060 X12 implementation guide, including explaining the reasoning for any that were not integrated.
Starting in the first quarter of 2026, X12 will host a series of webinars and provide on-demand computer-based materials to assist implementers with their assessments of the updated implementation instructions included in the 008060 versions. X12 is also in talks with some large-volume X12 member organizations who are considering sharing high-level information about their proprietary analysis findings as a joint project with X12.
If it would be helpful, X12 is ready to assist the National Standards Group (NSG) as it completes the cost analysis that accompanies a Notice of Proposed Rulemaking.
Related to the requirement to consult with the organizations named as DSMOs in the HIPAA regulations, representatives from all DSMO organizations have the opportunity to actively participate in X12 collaborations at Standing meetings and interim conference calls. In addition, since X12 implemented its new maintenance request process several years ago, representatives from other DSMO organizations have direct access to maintenance request information on X12's public-facing website. X12 will send a letter to the National Standards Group, each DSMO organization, and WEDI to inform them of this recommendation.
X12 looks forward to discussing this recommendation in more detail with many healthcare stakeholders over the coming months. Don't hesitate to get in touch with me anytime if you need more information or have any related questions.
Sincerely,
Cathy Sheppard
Cathy Sheppard
X12 CEO
csheppard@x12.org
cc: Michelle Barry, Accredited Standards Committee Chair, x12chair@x12.org