Change Request Detail
No.
1017
Date
12/17/2004
Submitter
Type of Request
Premium Payment to a Health Plan
Status
Appeal Denied
Business Reason
Implementation Specification as written can not be used with National Provider Identifier (NPI).  Page 73 [unmodified by Addenda] of 004010X061 specifies a value of "65" in ENT03 to indicate the National Employer Identifier is contained in ENT04. A value of "65" is not contained in Data Element 66 in X12 version 004010 ... or any later main versions to date for that matter.  It appears the best value for ENT03 would be "24"; however, "24" is not listed in the Implemenation Specification as a valid value for this data element.  Since it appears changes to future versions of this Implementation Specification will not be adopted for HIPAA in time to support the compliance dates for the NPI, a version 004010 change is required.
Suggestion
Update 004010X061 to allow a value of "24" in ENT03 in loop 2000A.
DSMO Category
B
Recommendation
Approved. The DSMO has recommended this change be incorporated into a future implementation guide. The current implementation guide version cannot be modified.
Appeal Recommendation
Appeal Denied: There is an HIPAA Interpretation Request (HIR) on the X12N Web Portal Website. Item 163 on this topic. At this time, the time, effort and cost does not bear the need for an addenda. Portal url:http://www.x12n.org/portal/ "Question: Page 73 of 004010X061 specifies a value of "65" in ENT03 to indicate the National Employer Identifier is contained in ENT04. A value of "65" is not contained in Data Element 66 in version 004010 ... or version 005010 for that matter. What value should be used in ENT03? [Note: Some untraceable sources at this time have stated to use a value of "24" in ENT03; however, "24" is not listed as a valid value in the referenced IG.] Portal Response: We recognize that we have a technical error, where the Implementation Guide requires the use code 65 once the National Employer Identifier is adopted. But, code 65 was never added to the standard. Consequently, use of the code 65 is not permissible, without violating the standard. Portal Recommendation: Since the standard and the Implementation Guide both support code FI, we recommend that as a work around solution, code FI should be used to identify the new National Employer Identifier. This is not all that illogical, since FI is the code for the Employer Tax Identifier, and as it turns out the National Employer Identifier is also the Federal Tax Identifier."