To clarify, CMS did not change the actual implementation date of HIPAA 5010. Providers must still comply with the 5010 transaction standards by January 1, 2012 and small health plans have until January 1, 2013. So if providers submit claims to small health plans, they have until January 2013.
CMS also simply decided it will not take any enforcement actions until March 31, 2012, if they receive any complaint against the covered entities for non-compliance. Many covered entities are still waiting for software updates.
CMS will accept complaints related to compliance between January 1 and March 30, 2012. Covered entities will have to provide evidence that they are complying or are making a good faith effort to comply with the new HIPAA standards during the 90-day period if asked.
The 90-day delay will not affect the implementation date for the ICD-10-CM/PCS coding systems. That date remains October 1, 2013. All HIPAA covered entities are required to switch to HIPAA 5010 in preparation for the conversion to ICD-10-CM/PCS.
See agency announcement on November 17 here.
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