Implementation of the NCPDP Standards for HIPAA II 11/2014 Slide 2-4 – see important implementation information on Quantity Prescribed 1 Telecom D.0 Imp Guide Enhancement for Rule Making Implementation Guide Enhancement (2012) An issue was brought to NCPDP’s attention by CMS regarding an OIG audit and Prescription Drug Event (PDE) reporting on Schedule II Controlled Substance claims. Based on numerous discussions, a recommendation was approved in November 2012 to support the use of the Quantity Prescribed (46Ø-ET) in Telecom claims. This has resulted in the republication of the Telecom Imp Guides from version D. Ø forward. See Members Section, Standards Download http://www.ncpdp.org/Members/Standards-Lookup for the November 2012 publication of the Telecommunication Imp Guide version D. Ø. NCPDP has requested the Department of Health and Human Services proceed with rulemaking process to name this version. Please check http://www.ncpdp.org/Resources/HIPAA under Implementation Guide Corrections banner for background and updates as known. NCPDP has notified to the best of our information all who were members (purchased guides) during this time and made the enhanced Telecommunication Standard Implementation Guide available. 2 Telecom D.0 Imp Guide Enhancement for Rule Making March 2013 OESS notified NCPDP to proceed; see letter at http://www.ncpdp.org/Resources/HIPAA under Implementation Guide Corrections banner. OESS thought they would publish a notice in the Federal Register. Early summer 2013 The Office of General Counsel advised OESS that it would not be a federal register notice. OESS created an Interim Final Rule (IFC) per ACA section 1104 on Administration Simplification. Later summer 2013 OGC advised OESS that ACA could not be used and the Telecom change would have to go through full rulemaking (Notice of Proposed Rule Making (NPRM) and Final Rule) process. Late 2014 CMS said the NPRM would be issued in early 2015. This delay of rulemaking has delayed the industry requested January 2014 implementation date. All entities are to put on hold the 01/2014 implementation of Quantity Prescribed changes until regulatory process has been invoked. 3 The HIPAA II Implementation of the NCPDP Standards 4 Pharmacy Standards Named Version upgrade: Telecommunication Standard Implementation Guide Version D.Ø (from Version 5.1) Batch Standard Implementation Guide Version 1.2 (from Version 1.1) New standard: Medicaid Subrogation Standard Implementation Guide Version 3.Ø Note: pharmacy industry utilizes the ASC X12 835 (remittance advice), 834 (enrollment) and the 270/271 (eligibility) is used in electronic prescribing 5 NCPDP Publication Change Since the advent of HIPAA, NCPDP has modified the publication of documents to allow industry flexibility in addressing new business needs in a regulated environment. In the past NCPDP created three types of documents. They were: Standard Implementation Guide Data Dictionary In old publications of documents, the above three documents were needed for implementation. 6 NCPDP Publication Change In the current environment, NCPDP publishes the following three types of documents: Standard Implementation Guide Data Dictionary External Code List The documents are used together, to provide a complete picture of the implementation of the standard. See the Matrix for the association http://www.ncpdp.org/NCPDP/media/pdf/StandardsMatrix.pdf See the “read me” document on the member CD or under “Standards Download” http://www.ncpdp.org/Members/Standards-Lookup (choose Telecommunication Standard) 7 NCPDP Standard Implementation Guide The Standard Implementation Guide contains the business and technical definition of the transactions the actual transaction layouts, the syntax and formatting rules, the transaction rules, usage, further information about the implementation of the standard by the use of descriptive paragraphs, business situations, examples, and frequently asked questions. This one document combines what was in the Standard and in the Implementation Guide in previous versions. 8 NCPDP Data Dictionary The Data Dictionary contains the actual field descriptions sizes, formats, comments, and usage instructions Which Data Dictionary do I use? See the Matrix http://www.ncpdp.org/NCPDP/media/pdf/StandardsMatrix.pdf (or on the member CD) Use of the correct publication of the data dictionary for a version of a standard is critical as each publication directs the proper use of a data element and data element values where applicable. 9 NCPDP External Code List The External Code List is a list of value codes with descriptions for data elements. The actual data elements still appear in the main Data Dictionary. The External Code List process allows values to be added to a data element without going through a ballot. The timeline to incorporate a value into a business need is shortened. Versions are upgraded quarterly if needed and are available for business use. 10 NCPDP External Code List Use of the correct publication of the External Code List for a version of a standard is critical as each publication directs the proper use of a data element and data element values where applicable. Which External Code List do I use? See the Matrix http://www.ncpdp.org/NCPDP/media/pdf/StandardsMatrix.pd f (or on the member CD) Important for understanding the rules for usage - See Understanding the External Code List Process at http://www.ncpdp.org/Members/Standards-Lookup (left side) 11 Process Overview for External Code List document • • Provides the process to request additions, modifications, and deletions to the data element values existing in the External Code List (ECL). This document contains an ECL Publication and Implementation Chart to provide key dates in which full ECL Publications and ECL Emergency Values should be implemented across all industry participants supporting the NCPDP Telecommunication Standard. Emergency Values Addendum • See the NCPDP Emergency Telecommunication External Code List Value Addendum document (http://www.ncpdp.org/Members/Standards-Lookup under External Code Lists. The addendum is listed under a quarterly ECL) for the list of values approved for emergency implementation and the ECL Publication and Implementation Chart. • Only applicable to Telecommunication Standard • Specific to regulatory requirements/mandates 12 External Code List Publication Recommendation • March 2Ø1Ø ECL publication should be the highest version in use when implementing the NCPDP Telecommunication Standard Version D.Ø to meet the January Ø1, 2Ø12 compliance date. – • • • This is an industry recommendation. It does not have force of regulation. Adoption of an annual ECL implementation schedule to incorporate up to four (4) ECL publications each year. Annual implementations are effective each October, starting with 2Ø12. ECL Publication and Implementation Chart provides key dates in which full ECL Publications and ECL Emergency Values should be implemented. 13 NCPDP Version D Editorial Frequently Asked Questions, Important Editorial Changes This document provides a consolidated reference point for questions that have been posed based on the review and implementation of the NCPDP Telecommunication Standard Implementation Guide and Data Dictionary for Version D. This document also addresses editorial changes made to these documents. Since the HIPAA-named Standards documents are "frozen" from changes, this document provides helpful FAQs, typographical changes and corrections, and further guidelines for implementation. This document is very important to implementers of the Telecommunication and Batch Standards, and Medicaid Subrogation Implementation Guide, as appropriate . Please continue to review this link as the document is updated as needed. This document is cited as a reference in the implementation guides, and guidance given in this document is to be implemented as standard. Is available on the HIPAA Public page http://www.ncpdp.org/Resources/HIPAA under Telecommunication Version D.0 banner, on the Standards Download page http://www.ncpdp.org/Members/Standards-Lookup and on the members CD. 14 Reference for What Changed Each document contains an appendix of the running list of changes Implementation guide Data Dictionary External Code List Version D Editorial Telecommunication Implementation Guide contains Matrices with legends for assisting with changes Appendix of changes from each version The Appendix containing Version D.0 changes also includes a section on “editorial” corrections which will be updated as needed. 15 Telecommunication Standard Implementation Guide Version D.Ø Supports the following processes (and others) 1. 2. 3. 4. Eligibility Verification Claim Service Information Reporting a. 5. 6. Not named in HIPAA, but is used in Medicare Part D True Out of Pocket (TrOOP) reporting and in Drug Utilization Review reporting Prior Authorization Predetermination of Benefits a. New transaction, not named in HIPAA but can be used to identify if the patient is eligible for prescription coverage, if the submitted product is covered, the patient financial responsibility at that point in time, and identify clinically relevant information that may influence the submission of a corresponding prescription claim request. b. Does not result in payment or application to the patient’s benefit. Transactions already named in HIPAA 1996. 16 What changed in Telecom? Field and Segment Defined Situations Fields and segments displayed as optional within the Implementation Guide were reviewed and determined, according to the transaction type and its associated response, to be “Not Used”, “Required if”, “Required”, or “Optional”. Fields and segments cannot be used in a manner other than as stated in the situations. This action was taken to address the situational versus optional data requirements discussed in the HIPAA Privacy Regulations. Request and Response Matrices The industry expanded the segment usage matrices to help clarify which segments and fields are sent for each transaction type. The segments and the fields within each transaction type have been very specifically defined. 17 What changed in Telecom? Medicare Part D enhancements – A new entity of Facilitator and the process of Informational Transactions enhanced. Eligibility Transaction enhanced for the Facilitator to provide patient eligibility information for Medicare Part D and other insurance coverage, Long Term Care Pharmacy claim processing enhancements to appropriately identify and process Medicare Part D claims. Medicare Part B enhancements – Three segments were added to allow for the processing of Medicare certificates of medical necessity. New data elements were added to allow for the items needed to process Medicare Part B transactions and assist in the crossover of claims from Medicare to Medicaid. 18 What changed in Telecom? The only method for billing of compounds is by the use of the Compound Segment. The two alternatives supported in previous versions for compounded claim processing were removed. Clarification for pricing guidelines. New fields were added and existing fields redefined to further clarify/correct the financial balancing of transactions. Coordination of Benefits (COB) Extensive clarification was made to the Implementation Guide for Coordination of Benefits processing. COB is more complicated with more complex rules than in the past. Specificity was given to the COB process by including new data elements such as patient responsibility and benefit stage fields as well as refining the use of the Other Coverage Code field. 19 What changed in Telecom? Prior Authorization Additional guidance was given for the Prior Authorization transactions with the addition of a new section to the implementation guide. Prescription/Service Reference Number (4Ø2-D2) was increased to 12 digits. Payer to Payer processing addresses the business needs of crossover and subrogation transactions and Information Reporting. Service Billings now have their own Transaction Code (S1, S2, S3). 20 Sections of Note in Telecom Each transaction set (Eligibility Verification, Claim Billings, Service Billings, etc) have their own section of explanation. Section contains Business and technical rules Segment diagrams for transmission Segment and field request tables with mandatory/situational rules for usage Segment and field response tables with mandatory/situational rules for usage Response Processing Guidelines Appropriate use of each response Pricing Guidelines 21 Sections of Note in Telecom Specific Segment Discussion Transmission Examples Frequently Asked Questions Appendix of Changes Important reference appendices 22 Batch Standard Implementation Guide Version 1.2 Version change (from 1.1 to 1.2) Editorial changes made A batch “wrapper” for the Telecommunication Standard Implementation Guide The same parsing routines can be used for the batch detail records as the real-time transactions For documents needed for implementation See the “read me” document (Batch Standard Implementation Guide information sections) on the member CD or http://www.ncpdp.org/Members/Standards-Lookup 23 Medicaid Subrogation Standard Implementation Guide Version 3.Ø New implementation guide named Medicaid Subrogation is a process whereby Medicaid is the payer of last resort. The state has reimbursed the pharmacy provider for covered claims and now is pursuing reimbursement from other payers for these claims. Some states may choose to “Pay” all claims in full, through a federal waiver, at the point of receipt and “Chase” reimbursements from responsible third parties after the fact. 24 Medicaid Subrogation Standard Implementation Guide Version 3.Ø The Medicaid Subrogation transactions use the Telecommunication Standard Implementation Guide transactions. May be real-time May be wrapped in the Batch Standard Implementation Guide The same parsing routines are used. For documents needed for implementation See the “read me” document (Medicaid Subrogation Standard Implementation Guide information sections) on the member CD or http://www.ncpdp.org/Members/StandardsLookup 25 Other Reference Guides For specific subject matter, other NCPDP documents may provide valuable information. These documents include: Billing Unit Standard Implementation Guide Pharmacy ID Card Implementation Guide Standards Matrix Information about these documents is available at http://www.ncpdp.org/Standards/Standards-Info and http://www.ncpdp.org/NCPDP/media/pdf/StandardsMatrix.pdf 26 Obtaining NCPDP Documents NCPDP receives its funding from membership. With a yearly membership, you receive all the implementation guides and associated documents for all the versions published. You receive any updates to these documents via the Members “Standards Download” section of the website. You receive industry activities information. You may attend the quarterly work group meetings at no charge as a member. You may attend educational programs and Annual Conference at member rates. We welcome your participation. See http://www.ncpdp.org/Membership 27 So what do I need to implement Telecommunication D.Ø? Members only section, Standards Download http://www.ncpdp.org/Members/Standards-Lookup (Choose Telecommunication in Search box) Telecommunication Implementation Guide Version D.Ø Data Dictionary dated 07/2007 Version D Editorial document (most current) and… 28 So what do I need to implement Telecommunication D.Ø? External Code List of 07/2007 through most current (recommendation to use most current) See Process Overview for External Code List document (slide 8 and 9) ECL Publication and Implementation Chart to provide key dates in which full ECL Publications and ECL Emergency Values should be implemented across all industry participants supporting the NCPDP Telecommunication Standard. Emergency Telecommunication External Code List Value Addendum document (slide 8 and 9) The addendum is listed under a quarterly ECL) for the list of values approved for emergency implementation and the ECL Publication and Implementation Chart. 29 So what do I need to implement Batch 1.2? Members only section, Standards Download http://www.ncpdp.org/Members/Standards-Lookup (Choose Batch, then Telecommunication in Search box) Batch Implementation Guide Version 1.2 Telecommunication Implementation Guide Version D.Ø Data Dictionary dated 07/2007 External Code List of 07/2007 through most current (recommendation to use guidance found under Telecom slides 8-9 if implementing Telecom transactions) Version D Editorial document (most current) 30 So what do I need to implement Medicaid Subrogation 3.Ø? Members only section, Standards Download http://www.ncpdp.org/Members/Standards-Lookup If real-time processing Medicaid Subrogation Implementation Guide Version 3.Ø Telecommunication Implementation Guide Version D.Ø Data Dictionary dated 07/2007 External Code List of 07/2007 through most current (Recommendation to use most current. Recommendation if using based on Telecom claim data, to use the Telecom recommendations on slide 8 and 9) Version D Editorial document (most current) If batch processing Batch Implementation Guide Version 1.2 Medicaid Subrogation Implementation Guide Version 3.Ø Telecommunication Implementation Guide Version D.Ø Data Dictionary dated 07/2007 External Code List of 07/2007 through most current (Recommendation to use most current. Recommendation if using based on Telecom claim data, to use the Telecom recommendations on slide 8 and 9) Version D Editorial document (most current) 31 Implementing ASC X12 Transactions Of note: Obtain ASC X12 Transactions http://www.x12.org/ or www.wpc-edi.com If using these transactions, obtain errata Errata for ASC X12 278 Health Care Services Review – Request to Review and Response Errata for ASC X12 837 Health Care Claim: Institutional Claims Errata for ASC X12 837 Health Care Claim: Dental Claims 32 FYI 33 Problem Solvers Task Groups are open to any interested party who are willing to participate and work Collaborative, focused, problem solving activities Work done via conference calls, email http://www.ncpdp.org/Standards/Standards-Info - lower left side 34 For Example These task groups handle responses to questions, scenarios are added to the Version D Editorial document usually quarterly http://www.ncpdp.org/Resources/HIPAA - under Telecommunication Version D.0 banner Telecommunication FAQ Task Group Handles questions from the industry about the Telecom Standard Coordination of Benefits (COB) Task Group handles questions submitted Popular subject, can be difficult Medicare Part D FAQ Task Group Reviews questions related to consistent application of Medicare Part D policy where claims or other applicable transactions, Prescription Drug Events (PDE) are involved. 35 For Example Information Reporting Problems Task Group Addresses processing problems with the Information Reporting transactions – specifically 4Rx Data (BIN, PCN, Group, Cardholder ID) used in processing for Medicare and supplemental payers). Collaboration with ASC X12 for transactions that impact pharmacy industry WG45 External Standards task groups for X12 270/271, 837, 835 transactions Long Term Care needs See WG14 Long Term Care and Post Acute Care task groups for short cycle dispensing, billing issues, return credit, automated dispensing and other functions being worked on. 36 Educational Activities NCPDP educational sessions http://www.ncpdp.org/Education/Webinar - and Archived webinars ASC X12 educational sessions ASC X12 developing individual educational program by transaction TR3 Conducting audiocast and face-to-face educational sessions www. http://www.x12.org/webinars/ Workgroup for Electronic Interchange (WEDI) educational sessions Obtain input from industry on NPRMs (Transactions and ICD10) http://www.wedi.org/ 37 Guidance NCPDP Strategic National Implementation Process (SNIP) HIPAA Implementation White Paper for NCPDP Standards Implementation Guide for Payer Sheets Consistent approach to sharing processing requirements http://www.ncpdp.org/Resources/Standards-Transition.aspx Payer (Plan Sheet) Templates - http://www.ncpdp.org/Resources/HIPAA under Telecommunication Version D.0 banner ICD-10 – http://www.ncpdp.org/Resources/HIPAA - under ICD-10 banner WEDI Timeline project lead by NCHICA and WEDI 835 implementation guidance Other papers as may be published 38 Thank you www.ncpdp.org 39
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