© 2010, Data Interchange Standards Association The Designated Standard Maintenance Organizations Process July 2010

© 2010, Data Interchange Standards Association 2 Overview What is the DSMO? What does this mean in English? How do I submit a change request? What happens next? Resources

© 2010, Data Interchange Standards Association 3 What is the DSMO? Designated Standard Maintenance Organizations (DSMO) –Organizations named by the Secretary (HHS) under HIPAA in § (a) to Maintain standards adopted under HIPAA Receive and process requests to adopt new standards or modify existing standards –Member Organizations are standards development organizations (SDOs) and data content committees Accredited Standards Committee (ASC) X12 Dental Content Committee of the American Dental Association (DeCC) Health Level Seven (HL7) National Council for Prescription Drug Programs (NCPDP) National Uniform Billing Committee.(NUBC) National Uniform Claim Committee (NUCC)

© 2010, Data Interchange Standards Association 4 What is the DSMO? Process for modification of existing standards and adoption of new standards must include: –Open public access –Coordination with other DSMOs –An appeals process for each of the following, if dissatisfied with the decision on the request: The requester of the proposed modification. A DSMO that participated in the review and analysis of the request for the proposed modification, or the proposed new standard. –Expedited process to address content needs identified within the industry, if appropriate. –Submission of the recommendation to the National Committee on Vital and Health Statistics (NCVHS)

© 2010, Data Interchange Standards Association 5 What is the DSMO? Process details defined through a Memorandum of Understanding (MOU) MOU defines Guiding Principles –Public access (single point of entry) –Timely review of change requests –Cooperation and communication –Consider all viewpoints –Evaluate impact of change requests –Maintain a national perspective –Conform to legislation

© 2010, Data Interchange Standards Association 6 What does this mean in English? Public access portal for the submission of requests to: –Modify existing standard transactions adopted under HIPAA –Request new standard transactions for adoption under HIPAA –e.g. new business need or data need –e.g. data needs change from current transaction Submission via Web or Paper –Web-based – reviewed in the following slides –Paper-based – see resources at end of presentation

© 2010, Data Interchange Standards Association 7 How do I submit a change request? Web-based process –Requester logs in to web site – requires creation of a login ID Captures name, address and contact information Needed in the event that additional clarification of request is needed during the review process Information available only to DSMO Secretary and Administrator –EXCEPT for address, which is viewable on the public Web site –Nothing else distributed to DSMO members Communication with requester generally occurs through the DSMO Secretary

© 2010, Data Interchange Standards Association 8 How do I submit a change request? Step-by-step process 1.Select request type 2.Enter Business Reason for change 3.Provide suggested revision to address the change 4.Receive DSMO Change Request (DSMO CR) ID # 5.Complete questionnaire form (X12N requests)  Identify additional guides that may be impacted by CR  Provide information relative to previous change request 1.CMS FAQs reviewed – Yes/No 2.Existing DSMO CRs reviewed – Yes/No 3.New request – Yes/No 4.Provide and related DSMO CR numbers

© 2010, Data Interchange Standards Association 9 How do I submit a change request? Step-by-step process (continued) 5.Complete questionnaire form (X12N requests)  Identify version, key page numbers and sections of the guide  Identify any specific areas and/or specialties of health care impacted by the request  Provide Subject Matter Expert and Alternate Contact information  Additional information regarding:  X12 group participation  X12 groups contacted  Other industry groups contacted  Information provided by any of the above

© 2010, Data Interchange Standards Association 10 Create a Log in ID

© 2010, Data Interchange Standards Association 11 Create a Log in ID

© 2010, Data Interchange Standards Association 12 Create a Log in ID

© 2010, Data Interchange Standards Association 13 Identify the Request Type

© 2010, Data Interchange Standards Association 14 Identify the Business Reason for the Change Request

© 2010, Data Interchange Standards Association 15 Identify the Suggested Solution for the Change Request

© 2010, Data Interchange Standards Association 16 Change Request Number Provided

© 2010, Data Interchange Standards Association 17 Provide Additional Detail for X12 Transactions: Other Implementation Guides Affected

© 2010, Data Interchange Standards Association 18 Provide Additional Detail for X12 Transactions: Research Conducted

© 2010, Data Interchange Standards Association 19 Provide Additional Detail for X12 Transactions: Specific Items Impacted in Implementation Guide

© 2010, Data Interchange Standards Association 20 Provide Additional Detail for X12 Transactions: Other Health Care Areas Impacted

© 2010, Data Interchange Standards Association 21 Provide Additional Detail for X12 Transactions: Requester Contact Information

© 2010, Data Interchange Standards Association 22 Provide Additional Detail for X12 Transactions: Other Input Received

© 2010, Data Interchange Standards Association 23 What happens next? DSMO Change Request Process –Allows DSMO members to opt-in or opt-out of a change request –Review Process generates batches on a monthly basis –DSMO Review is a 90-day cycle Details on the following slides –DSMO members may request one 45-day extension Details on the following slides –Requester or DSMO member may submit an appeal to the DSMO response Details on the following slides

DSMO Process Flow 90-day Batch Cycle © 2010, Data Interchange Standards Association 24 Submitter enters Change Request, receives ID # (DSMO CR #) Becomes part of the batch created the next month Monthly Batch created and DSMO Members notified 5 th business day of the Month DSMO Members Opt-in (or out) within 10 business days DSMO Members have 90- calendary days to deliberate and develop recommendation for the response May request additional information from the requester during this time One 45-day extension may be requested by any DSMO Member DSMO Members Review all recommended responses Reach a disposition on the DSMO CR Final Recommendation posted to the Web site Requester is notified that the DSMO recommendation has been posted Requester has 15 calendar days to appeal Yes No Appeal Submitted? DSMO CR is Final Recommendation sent to SDO Appeal Process See slide 29 CRs Appeal Remanded

© 2010, Data Interchange Standards Association 25 DSMO Response Categories A.Modifications necessary to permit compliance with the standard/law. According to DHHS, necessary items include: 1.Something in the adopted standard or implementation specification conflicts with the regulation. 2.A non-existent data element or code set is required by the standard. (removal of data content that is not supported by the healthcare industry any longer) 3.A data element or code set that is critical to the industry's business process has been left out. 4.There is a conflict among different adopted standards 5.There is an internal conflict within a standard (implementation guide).

© 2010, Data Interchange Standards Association 26 DSMO Response Categories B.Modifications. Classified as additions or deletions of data elements, internal code list values, segments, loops; changes in usage of segments, data elements, internal code list values; changes in usage notes; changes in repeat counts; changes in formatting notes or explanatory language that do not fall into Category A. C.Maintenance. Classified as items that do not impact the implementation of the transaction. Items classified as Maintenance will require no further DSMO actions. Items are to follow the SDO process. D.No Change. Classified as items that the implementation guides do meet the needs requested, or did go through the consensus building process originally to meet need. May request follow up by the submitter for further action.

© 2010, Data Interchange Standards Association 27 DSMO Response Categories E.DHHS Policy. Classified as items that require follow up by the Department of Health and Human Services in regards to the Final Rule. F.Withdrawn by Submitter. Classified as items that have been removed from Change Request System consideration. G.Appeal. Classified as items where the DSMOs did not reach consensus on response and will follow the appeal process.

© 2010, Data Interchange Standards Association 28 DSMO Response Categories H.Industry Comment Request Process. Classified as items that require comments from the industry to determine consensus. I.Recommendation for adoption of new/modified HIPAA standard. Classified as items that result in the recommendation to the National Committee on Vital and Health Statistics for the adoption of a new/modified HIPAA standard. Examples might include a request for a new transaction, or a new version or release of an already-named standard for a given transaction(s). J.Out of DSMO Scope. Classified as items that are not in the scope of the DSMO. An example is change requests for modifications to transactions not named in HIPAA.

DSMO Appeal Process © 2010, Data Interchange Standards Association 29 Appeal Process Requester submits additional supporting documentation on their appeal Within 15 calendar days of Appeal declaration deadline DSMO Members deliberates appeal using additional information submitted Reaches disposition on the appeal within 30 calendar days Requester is notified of the final DSMO recommendation Denied Upheld Remanded to DSMO Members CRs Denied Slide 30 CRs Upheld Slide 31 CRs Appeal Remanded Slide 24 One of three decisions

DSMO Appeal Process: Appeal Denied © 2010, Data Interchange Standards Association 30 CRs Denied Denied Requester can file another CR with more information Requester can file comments in response to a NPRM No further action by Requester One of four actions Requester can discuss further with NCVHS NPRM = Notice of Proposed Rulemaking

DSMO Appeal Process: Appeal Upheld © 2010, Data Interchange Standards Association 31 CRs Upheld Upheld The DSMO will re-categorize the Change Request and provide a new recommendation Final Recommendation sent to SDO

© 2010, Data Interchange Standards Association 32 DSMO Appeal Process Response Categories Appeal Outcome Available Soon Appeal Withdrawn Appeal Upheld Appeal Denied Appeal Remanded

© 2010, Data Interchange Standards Association 33 Resources DSMO Web site ASC X12ADA DeCC NCPDPNUBC HL7NUCC

Resources: To Submit Change Requests via Mail Transaction Typ ing AddressFacsimile Number Retail Pharmacy Transactions National Council for Prescription Drug Programs 9240 East Raintree Drive Scottsdale, AZ (480) Attachment Booklets Health Level Seven, Inc Washtenaw Avenue Suite 227 Ann Arbor, MI (734) All Other Transactions Washington Publishing Company NE 33rd Place Suite 204 Bellevue, WA (775) © 2010, Data Interchange Standards Association 34