Illinois Hospital Association

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June 19, 2008

Health Information Technology Issues

Federal HIT Initiatives
Over the past 18 months, information technology and standard developments have slowed down considerably at a federal level. During this time, the American Health Information Community, chartered in 2005 to make recommendations to the Secretary of the U.S. Department of Health and Human Services on how to accelerate the development and adoption of health information technology, has been migrating from a government entity to a public-private organization. AHIC anticipates being up and running some time late this fall.

On June 3, 2008, the Office of the National Coordinator on Health Information Technology (ONCHIT) released a coordinated federal Health IT Strategic Plan for 2008-2012 (see http://www.hhs.gov/healthit/). In this plan, were goals and objectives outlined for achieving very ambitious initiatives but without much information provided as to support and resources needed for success achievement of the goals and objectives. While the report reiterates the target date of 2014 set by President Bush to have Electronic Health Records in health care, it provides little support as to how this will be achieved by health care providers.

In recent days with the American Medical Association holding their annual convention, there has been a great deal of discussion about the slow and low rate of transition to Electronic Health Records by physicians. While physicians recognize the value of EHRs, the financial resources and support are not available to aid in this transition. Similarly, many hospitals would like to take advantage of the benefits of EHRs, but the resources available to implement and provide ongoing support do not exist.

While the need for Electronic Health Records is very apparent among health care providers, the lack of health IT standards and financial support are slowing down progress considerably.

National Provider Identifier
Medicare While there have been some glitches in getting hospital claims processed by Medicare with the May 23 implementation of the National Provider Identification Number; Medicare is continuing to address these issues on a case by case basis.

Medicare has asked IHA to alert hospitals that slow downs on hospital claims processing could be a problem if hospitals have not yet addressed the following issues. The information below is from Medicare:

Medicare FFS NPI Update & Part B Issues Identified
As of 5/23/08, the National Provider Identifier (NPI) became mandatory on all HIPAA claims transactions and on Medicare paper transactions as well.  All transactions must be submitted with the NPI in fields requiring a provider identifier (see items 1-3 below concerning the reporting of the Taxpayer Identification Number (TIN)).  The Centers for Medicare & Medicaid Services (CMS) continues to see progress with NPI compliance and most Medicare contractors are reporting over 95 percent of claims contain only NPI. However, for some of the relatively few claims which continue to reject, we have determined that some of the reasons are related to the following issues identified for Part B claims:  

1)  The Employer Identification Number (EIN) or Social Security Number (SSN) being submitted in the 2010AA / REF02 (Billing Provider Secondary Identifier), 2010AB / REF02 (Pay to Provider Secondary Identifier) and/or 2310B / REF02 (Rendering Provider Secondary Identifier) of the Medicare X12N 837P transaction does not match the TIN information on the Medicare crosswalk.   

2)  While EIN or SSN is not required to be submitted in the 2310B loop for Medicare claims, if submitted, the appropriate qualifier must be submitted in the 2310B / REF01. 

      - Qualifier EI must be submitted in the 2310B / REF01 when an EIN is being submitted in the REF02.
     - Qualifier SY must be submitted in the 2310B / REF01 when an SSN is being submitted in the REF02. 

3)  The Medicare legacy provider identifier is being submitted in the primary and/or secondary provider loops.  Legacy provider numbers are no longer allowed on ANY Medicare claim or transaction.  If sent, the claim or transaction will reject.

Medicare providers should review this list and take appropriate actions to resolve problems they may be experiencing.  As a result, providers may decide to stop sending non-required segments, such as the TIN in 2310B/REF02 of the X12N 837P transaction.  Providers may also want to consult their clearinghouses or software vendors for additional advice to solve the issues listed in this message. 

Medicaid - Hospitals On a state level, Illinois hospitals have not experienced any major glitches with Medicaid or commercial health plan claims processing. However, HFS (Illinois Medicaid) has urged hospitals with any claim rejections (normal errors and rejections) from May 2, through June 9, 2008; hospitals must re-submit claims that required manually system override for processing that were received during this period will need to be resubmitted.

Unfortunately, according to HFS, "claims requiring manual intervention (e.g., for timely filing, Part A benefits exhaust, HSI exceptions) were put through the claims system and have been denied (with error codes e.g., D05, R35, & A88). HFS is not able to identify and reprocess the affected claims. Hospitals are urged to check with their billing consultants and to resubmit any affected claims."

Medicaid – Physicians However, physicians are experiencing some slow downs in their processing of claims to Medicaid. To help get the word out for physicians to obtain their reimbursement, hospitals should remind physicians that both group practices and individual physicians must obtain separate NPIs for Medicaid processing. While we know hospitals are not responsible for physician billing, if your physician is experiencing problems in getting their claims paid as a result of the NPI, we ask that you share this information with them.

Medicaid Cross Over Claims According to HFS: "HFS has been informed by The Centers for Medicare & Medicaid Services (CMS) that a number of Coordination of Benefits Agreement (COBA) trading partners, such as HFS, are having difficulty accepting 837 professional crossover claims where the 2310A loop ("Referring Physician") NM108 and NM109 segments are blank and also missing the accompanying "REF" segment. Providers would have transmitted these professional claims to Medicare prior to May 23, 2008, without a NPI. The Coordination of Benefits Contractor (COBC) has no method for re-sending these already transmitted claims with the 2310A, REF

segment included. Therefore, a large number of 837 professional crossover claims were not accepted by HFS because of the HIPAA compliant translator programming that exists. This notification is to inform the providers that it will be necessary for them to resubmit these claims directly to HFS.

These claims can be resubmitted in one of the following formats; 837P (Professional), HFS 3797 paper claim form, or by using the 3797 Direct Data Entry (DDE) through our MEDI/IEC site www.myhfs.illinois.gov.

Effective with claims submitted to Medicare on our after June 11, 2008, the COBC will no longer transmit claims that do not contain a NPI value where required."

If you have questions on any of the items in this memo, please contact Pat Merryweather at pmerryweather@ihastaff.org. Thank you.