Frequently Asked Questions
Who should submit a "compliance plan"
to DHHS to obtain a one-year extension for compliance
with the Transactions and Code Sets regulations?
- "Compliance plan": As
mentioned above, covered entities must either be in
compliance with the Transactions and Code Sets regulations
by October 2002 or submit a compliance plan
to DHHS by October 2002 in order to obtain a one-year
compliance extension. The agency responsible for receiving
these compliance plans is the DHHS Centers for Medicare
and Medicaid Services (CMS). These compliance plans
are fairly simple and straightforward. The plan requires
responses to several questions related to an entity's
progress in implementing the Transactions and Code
Sets regulations, the reason(s) that the entity needs
a one-year extension (e.g., limited funding), and
the entity's projected timeline for completing implementation.1
- "Implementation plan":
CMS has indicated that a compliance plan should be
submitted on behalf of an entity or portion of
an entity that is participating in the "implementation
process" or "implementation plan."
It is permissible to submit several compliance plans
for a single covered entity if different components
of the entity are implementing the Transactions and
Code Sets regulations in different ways or on different
schedules.
- Example: Assume that an entire
county is a covered entity and the local health department,
department of social services and emergency medical
services department all have different software vendors
and therefore are all operating on different timelines
for implementing the Transactions and Code Set regulations.
These departments have different processes for implementing
the regulation and therefore their responses to questions
on the compliance plan form, such as their expected
completion dates, will be different. The county (or
the departments on behalf of the county) would then
submit separate "compliance plans" for each
of these departments in order to obtain the extension.
Back to Top
1The compliance form is
available electronically and may either be submitted
via the Internet or on paper. See http://www.cms.gov/hipaa/hipaa2/ascaform.asp).
Back to FAQs |
