In late September, the Centers for Medicare and Medicaid Services (CMS) announced it would implement a contingency plan to accept non-HIPAA-compliant transactions after the October 16 deadline -- but only for a limited time.

Contingency plans will be discontinued once the majority of providers are able to submit HIPAA-compliant claims, also known as 837 transactions.

Blue Cross Blue Shield of Massachusetts (BCBSMA) quickly followed the CMS announcement with a similar plan to continue to accept nonstandard claim submissions. Other insurers and HIPAA-covered entities have done the same as a temporary solution, providing a smooth transition for health care providers.

To ensure that cash flow continues without disruption, physician practices should be working closely with practice management software and clearinghouse vendors to test and implement HIPAA transactions as soon as possible. It is also recommended that practices document all communications with software vendors, clearinghouses and health plans to illustrate a good faith effort on the part of the practice to meet HIPAA compliance.

If your practice is not currently submitting HIPAA-compliant claims, contact your software vendor, clearinghouse and health plans to determine how to properly submit your claims for payment.

If you encounter problems or need additional guidance to comply with the HIPAA TCS regulation, visit the Physician Practice Resource Center at www.massmed.org/pages/pprc.asp or call (800) 322-2303, ext. 7218 or 7702.

- Scott Jauch

Attorneys with knowledge of HIPAA and its accompanying regulations should be consulted regarding the application of these laws to specific situations.