Where to Request Changes?
One of the early points of concern was the issue of where to request a change to the transaction standards and the code sets they refer to. Within the legislation and the final rule there are organizations designated by the Secretary of Health and Human Services that are involved with the development and maintenance of the transaction standards. They include three ANSI accredited Standards Development Organizations, ASC X12, Health Level 7 (HL7), and National Council for Prescription Drug Programs (NCPDP); and three data content organizations, the National Uniform Claim Committee (NUCC), the National Uniform Billing Committee (NUBC), and the Dental Content Committee (DeCC) of the American Dental Association (ADA). These six organizations are collectively called the Designated Standards Maintenance Organizations (DSMO).
The DSMO signed a Memorandum of Understanding (MOU) that outlined a framework of cooperation between and among HHS and the Standards Development Organizations (SDO) and Data Content Committees (DCC) designated by the Secretary of HHS (the Secretary) to play an active role in the HIPAA Administrative Simplification transactions maintenance process. These organizations agreed to work together to manage the change request process affecting the transaction standards adopted by HHS under HIPAA. This includes all necessary and appropriate modifications to the standard implementation guidelines/manuals and documentation as well as the related data dictionaries. It also includes review of requests to add new functionality or new transactions to the HIPAA standards.
It is important to note that the DSMO was set up to process change requests to the transactions and code sets. There are other administrative simplifications under HIPAA (such as privacy, security, etc) that are outside the DSMO charge.
Changes to federally adopted standards for transactions and code sets can also be made directly to the applicable organization named above. Each organization has a process for requesting changes/additions directly. Standard Development Organizations (X12, HL7 and NCPDP) encourage active participation within their standards development process.
In addition to the change request process, DSMO coordination also includes consultation with governmental organizations including the Department of Health and Human Services and the National Committee on Vital and Health Statistics including annual change summaries and recommendations relative to the changes that have been submitted to the change request system.