s a vendor, one of the considerations we had as we developed the 5010 270 transaction was to follow the rule for Primary Search Option. Our interpretation of the use of the Primary Search Option is when all 4 data elements are present the Information Source is obligation to send a response. Our logic does monitor for all of the stated elements and if one is missing, we send the other (Secondary) elements.
We do send all 4 data elements, but even with those in the transaction, some third parties/payers have required the provider submit additional 'Secondary Search Option' data as they are unable to send a response without that additional data. My understanding is that it is up to the Provider to determine what Secondary data they will submit, and it is not for the third party/payer (Information Source) to not send a response without the additional data. Is my interpretation correct? If so, how do we get the 'Information Source' to not require these secondary elements?
Yes, your interpretation is correct. This issue is explicitly addressed in guide 005010X279 in section 1.4.8.1. Required Primary Search Option.
“If the patient is the subscriber, the maximum data elements that can be required by an information source to identify a patient in loop 2100C are:
Patient is Subscriber
Patient's Member ID (or the HIPAA Unique Patient Identifier if mandated for use)
Patient's First Name
Patient's Last Name
Patient's Date of Birth”
“If the patient is a dependent of a subscriber, the maximum data elements that can be required by an information source to identify a patient in loop 2100C and 2100D are:
Loop 2100C
Subscriber's Member ID
Loop 2100D
Patient's First Name
Patient's Last Name
Patient's Date of Birth”
A health plan (information source) may not require a provider to submit any information beyond the four pieces of information identified in the Primary Search Option section. Any additional (secondary) information may be submitted at the provider’s discretion.
In your request, you asked “how do we get the 'Information Source' to not require these secondary elements?” If working with the Information Source does not correct this issue, you may choose to explore filing an official compliance complaint at the following link: