|
In
its guidance issued July 24, 2003, CMS outlined its approach
to enforcement of the law:
-
CMS
will focus on obtaining voluntary compliance and use a complaint-driven
approach for enforcement of HIPAA’s Electronic Transactions
and Code Sets provisions.
-
This
compliant-driven enforcement approach allows CMS to consider
the “good faith” efforts of health plans to
achieve compliance and in deciding how to implement enforcement
actions on a case by case basis.
FOX
Systems, Inc. (FOX).has
tailored its set of services to address the needs of clients
still conducting good faith preparations for compliance. FOX
is a national leader in understanding the steps to be taken
to achieve a level of compliance that is appropriate to meet
the requirements in the law. If you are not already compliant,
then now is the time to take steps to address the risk of
non-compliance.
CMS
will not impose penalties on covered entities that deploy
contingencies (in order to ensure the smooth flow of payments)
if they have made reasonable and diligent efforts to become
compliant and, in the case of health plans, to facilitate
the compliance of their trading partners. Health plans must
ensure that they are taking action and making progress toward
compliance. Most importantly, health plans must be aware of
provider efforts to become complaint, and must facilitate
their efforts to be compliant by the deadline. It is important
for all non-compliant covered entities to be working on compliance
activities and to document these steps to be able to demonstrate
“good faith efforts”.
Examples
of good faith efforts include:
-
Outreach
efforts with providers and trading partners
-
Measured
levels of external testing with trading partners.
-
Assessment
of providers and trading partners readiness to test and
meet the deadlines.
-
Reasonable
best efforts to implement compliance as soon as possible.
-
Development
and preparedness to implement contingency plans to ensure
the smooth flow of payments between health plans and providers.
-
Translator
and Interface Development
- Clearinghouse
Procurement and Implementation
-
EDI
Testing and Help Desk Support
-
Compile
Resources and Develop Materials to Expedite Training
-
Develop
Phased Level Approach for Handling Non-Compliant Transactions
FOX
can
help ensure that organizations make good faith, documented
efforts to achieve compliance. FOX has assisted health plans
in over 11 states in strategic and operational planning for
HIPAA readiness and implementation.
FOX
has tailored a segment of its HIPAA Transactions and Code
Sets (TCS) consulting and implementation support services
for health plans which are behind the HIPAA implementation
curve and have achieved only partial compliance and which
need to “catch up” as their major trading partners
achieve compliance status.
Our
services address the following three areas of need:
Planning, Management and Assessment
FOX
has been a leader in HIPAA assessment and gap analysis, and
this experience can be invaluable in making informed decisions
on eleventh hour issues that may affect health plan compliance.
Our
Planning, Management, and Assessment services include:
-
Assessment
and Reassessment of HIPAA Compliance Plans and Project Documentation
-
Impact Assessment and Business Continuity Planning
-
Project Assessment and Quality Assurance Oversight
-
Compliance
Strategy Definition
-
Contingency
Plan Development
TCS Implementation
and Support Services
FOX helps health
plans with a wide range of implementation services to develop
and implement effective solutions to achieve compliance. We
are ready to supplement your efforts to be ready on time.
Key
elements of TCS Implementation and Support Services tasks include:
- Transactions and
Code Sets (TCS) analysis and mapping
- Local coding analysis
and solutions
- TCS implementation
support
- Translator
and interface development
- Clearinghouse
procurement and implementation
- EDI testing
and Help Desk support
- Compile resources
and develop materials to expedite training
- Develop phased
level approach for handling non-compliant transactions
Trading Partner
Implementation Services
The centerpiece
of implementation is outreach and communications with providers
and trading partners. FOX has been a leader in provider outreach
and training, and we are experienced in readiness assessment
and supporting external testing activities. These efforts are
an essential element in health plan “good faith efforts".
Key
elements of Trading Partner implementations include:
- Trading partner
readiness assessment
- Trading partner
communications and training
- Companion guide
development
- Trading partner
/ provider outreach
- Trading partner
agreement administration
FOX
is ready to help you achieve compliance and implement enforcement
activities. We have the knowledge, skills and experience needed
to assist you. Contact us today to accelerate your progress
toward HIPAA compliance!
|
