Health Care Attachments to Support Claims, Referrals and Authorizations

Type	Standard / Implementation Specification	Standards Process Maturity	Implementation Maturity	Adoption Level	Federally required	Cost	Test Tool Availability
Implementation Specification	ASC X12®N/006020X315 Health Care Services Request for Review and Response (278), September 2014 as an ASC X12 Standards for Electronic Data Interchange Technical Report Type 3	Final	Production		No	$	No
Implementation Specification	ASC X12N/006020X313 Health Care Claim Request for Additional Information (277), September 2014 as an ASC X12 Standards for Electronic Data Interchange Technical Report Type 3	Final	Production		No	$	No
Implementation Specification	ASC X12N/006020X316 Additional Information to Support a Health Care Services Review (275), September 2014 as an ASC X12 Standards for Electronic Data Interchange Technical Report Type 3	Final	Production		No	$	No
Implementation Specification	HL7 CDA® R2 Attachment Implementation Guide: Exchange of C-CDA Based Documents, Release 1 - US Realm	Final	Production		No	Free	No
Implementation Specification	HL7 CDA R2 Implementation Guide: Consolidated CDA Templates for Clinical Notes (US Realm) Draft Standard for Trial Use Release 2.1	Final	Production		No	Free	No
Implementation Specification	HL7 FHIR DaVinci Clinical Data Exchange (CDex) Implementation Guide	Balloted Draft	Pilot		No	Free
Implementation Specification	NCPDP SCRIPT Standard Implementation Guide Version 2023011	Final	Production	Feedback Requested	No	$	No

Limitations, Dependencies, and Preconditions for Consideration	Applicable Security Patterns for Consideration
The HIPAA legislation requires adoption of a standard for health care attachments; the Affordable Care Act of 2010 reiterated this requirement. HHS has not proposed adoption of a standard for attachments to support claims and other administrative transactions to date (11/2021). Willing trading partners may exchange attachments through methods agreed upon by those organizations, including through different means of electronic exchange, and the use of standards. Pilots to test new standards for consideration to be adopted under HIPAA is permissible using the exception process under 162.940. CMS provides additional information about the HIPAA administrative simplification provisions on its website. HL7 DaVinci is testing an exception to the x12 278 with an API and submitted its report in July 2024.	Feedback requested.

Limitations, Dependencies, and Preconditions for Consideration

Applicable Security Patterns for Consideration

The HIPAA legislation requires adoption of a standard for health care attachments; the Affordable Care Act of 2010 reiterated this requirement. HHS has not proposed adoption of a standard for attachments to support claims and other administrative transactions to date (11/2021). Willing trading partners may exchange attachments through methods agreed upon by those organizations, including through different means of electronic exchange, and the use of standards.
Pilots to test new standards for consideration to be adopted under HIPAA is permissible using the exception process under 162.940.
CMS provides additional information about the HIPAA administrative simplification provisions on its website.
HL7 DaVinci is testing an exception to the x12 278 with an API and submitted its report in July 2024.

Feedback requested.

Comment

Submitted by pwilson@ncpdp.org on 2024-08-13

NCPDP Comment

NCPDP recommends that ASTP/ONC add NCPDP SCRIPT Standard Version 2023011. Pharmacy service referral transactions are published in that version.
NCPDP Recommends adding the following:

Type-Implementation Specification

Standard Implementation/Specification- NCPDP SCRIPT Standard Implementation Guide Version 2023011

Standards Process Maturity – Final

Implementation Maturity – Published

Adoption Level – N/A

Federally required – Yes

Cost - $

Test Tool Availability – No

Submitted by pwilson@ncpdp.org on 2023-10-06

NCPDP Comment

NCPDP recommends that ONC sunset NCPDP® SCRIPT Standard Implementation Guide Version 2020101 as this version is not supported by the industry.
NCPDP recommends that ONC remove from Limitations, Dependencies, and Preconditions for Consideration section: Pharmacy referral transactions have been published in the NCPDP SCRIPT Standard Version 2020101. These transactions are currently available for use by trading partner agreement. Authorizations are also available in NCPDP SCRIPT Standard Version 2017071. The SCRIPT transactions can handle a single attachment that can contain multiple documents.

Submitted by shellyspiro on 2023-10-02

Pharmacy HIT Collaborative (PHIT) comment

PHIT supports NCPDP’s recommendation of adding NCPDP SCRIPT Standard, Implementation Guide, Version 2022011 to the implementation specification.

Submitted by pwilson@ncpdp.org on 2021-09-29

NCPDP Comments

Add the following:

Type-Implementation Specification

Standard Implementation/Specification- NCPDP SCRIPT Standard Implementation Guide Version 2020101

Standards Process Maturity – Final

Implementation Maturity – Published

Adoption Level – N/A

Federally required – No

Cost - $

Test Tool Availability – No

Referral transactions published in the NCPDP SCRIPT Standard Version 2020101. These transactions are currently available for use by trading partner agreement.
Authorizations are currently available in NCPDP SCRIPT Standard Version 2017071. The SCRIPT transactions can handle a single attachment that can contain multiple documents.

Submitted by pwilson@ncpdp.org on 2020-11-07

NCPDP Comment

Add the following:

Type-Implementation Specification

Standard Implementation/Specification- NCPDP SCRIPT Standard Implementation Guide Version 2020101

Standards Process Maturity – Final

Implementation Maturity – Production

Adoption Level – 1

Federally required – No

Cost - $

Test Tool Availability – No

Referral transactions published in the NCPDP SCRIPT Standard Version 2020101.

Submitted by pwilson@ncpdp.org on 2019-09-24

NCPDP Comment

Emerging Transaction(s) within NCPDP SCRIPT Standard:
1. Patient Care Service Referral (ServiceReferral)
2. Patient Care Service Documentation (ServiceDocumentation)
3. Response to Request for Patient Care Service Referral (ResponseToReferralRequest)
4. Request for Patient Care Service Referral (RequestForReferral)
5. Response to Patient Care Service Referral (ServiceReferralResponse)

Submitted by mattreid on 2019-09-23

Acknowledgments

The American Medical Association appreciates the opportunity to comment. This section includes acknowledgments, however, acknowledgments typically does not support claims, referrals, or authorizations. We believe acknowledgments is misplaced in this section. We understand the reasoning could be because they are lumped together on the regulatory agenda, however the 999 does not seem related. Acknowledgments intersects with multiple transactions, therefore we believe it should have its own section. The guidance claims that two payers have successfully implemented attachments after piloting in 2004. This is inaccurate as the standard that is currently under consideration was not created until 2016.

Submitted by pwilson@ncpdp.org on 2018-10-01

NCPDP Comment

Request removal of NCPDP 2017 comments.

Submitted by dvreeman on 2017-11-20

The very large list of…

The very large list of standards in this section suggests that it should be broken up into different interoperability needs. There also seems to be a mix of base standards (X12 Version 6020), implementation guides specific to attachments, and some other general implementation guides that probably don’t need to be listed here because they are pointed to in the attachment specific guides (C-CDA, LOINC Document Ontology IG, Digital signatures, etc). Previously, the HITSC recommended separating out base standards from implementation guides.

Submitted by Brett Andriesen on 2017-12-13

CMS Response:

CMS Response: Thank you for this comment. It is true that this proposed set of standards pertaining to attachments specifically represents a wide range of base standards and implementation guides. When the regulation is published, industry will have an opportunity to comment on the use of this proposed suite and will look forward to engaging further at that point. In the meantime, we will hope there will be an increase in their voluntary use and pilots. We would be interested in hearing more about different ways in which these could be broken out by different interoperability needs.