Change Request Detail
No.
1094
Date
2/18/2010
Submitter
Type of Request
Pertaining to more than one, or not sure
Status
DSMO Process Completed
Business Reason
We have a high cost estimate for implementing data element N407 (Country Subdivision Code) in the HIPAA 5010Version and would like to understand the rationale and original intent for adding this data element.  Please provide the purpose and who will be benefiting from the use of this data element.  Even as an entity that has many person and non-person addresses outside the United States, we currently don't see a benefit or use of this data element in our provider or payer processes.

Here, below, is some background information that we've been able to obtain or glean:

* An X12 DM for v4020 was approved in 1998 for addition of Country Subdivision Codes, referencing ISO 3166 Part-2. 

    ** X12 reps (Laurie Burckhardt and Gail Kocher) were unable to locate the original DM in order to state the original intent and purpose of adding the data element.

* The situational rule for Country Subdivision Code data elements in v5010 TR3's specifically says that the subdivision code is required in data element N407 if the country (non-US and non-Canada) identified in data element N404 has Country Subdivision Codes.  Many countries "do" have subdivision codes (e.g., Germany and England).

* Data element N407 applies to a wide range of postal addresses (organizational addresses, provider addresses, subscriber addresses, patient addresses).

     ** Previous answers to our email queries state (in part) that, "The reporting of a subdivision code for a country other than US and Canada, e.g. Italy in N402 in 005010 is out of compliance with the X12 standard and implementation because the Code Source available in N402 does not include the subdivisions of Italy and the situational rules for N402 and N407 require it be reported in N407 and require it not be reported in N402."

         *** The problem with this answer, is that N407 is not tied to N402 (State or Province if U.S. or Canada), instead the v5010 TR3's situational rule ties N407 usage to whether the N404 (Country Code) has subdivisions.

* Strict compliance with the letter of HIPAA v5010 guides (834, 271, 837) requires the use of Country Subdivision Codes for any non-US and non-Canada country that is identified in data element N404 which has ISO 3166 subdivision codes.  However, because the DM was approved in 1998 for X12 v4020, and since X12 reps don't appear to be able to access the approved DM, we don't know the original intent for use of the codes.

Could you help us, and the broader industry, understand the intent, purpose, and use of this data element in the TR3ís?  If there is no known or documented reason for N407 (Country Subdivision Code), we recommend that X12 remove this situationally required data element.
Suggestion
Remove data element N407 (Country Subdivision Code) from all HIPAA 5010 Version transactions.
DSMO Category
D
Recommendation
Disapprove.  N407 cannot be removed from the TR3 because it is part of the X12 standard.  The N407 data element is the only data element in the N4 segment in which the equivalent state/province may be transmitted for countries other than U.S., U.S. territories, Canada, and Mexico. The X12 standard only allows Code Source 22 for element N402. Code Source 22 only includes subdivisions for U.S., U.S. Territories, Canada, and Mexico. Thus, per the X12 standard, subdivisions for other countries that have them cannot be sent in N402, e.g. departments in France and cantons in Switzerland. A TR3 is not allowed to override the X12 standard. The Health Care Task Group (TG2) also elected to use N407 to report Mexican state codes since the reference for Mexico in Code Source 22 is not an international standard, but a transportation specific code set.
Appeal Recommendation