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The Centers for Medicare & Medicaid Services (CMS) issued a model compliance plan that will allow health plans, health care clearinghouses and health care providers to receive a one-year extension to comply with the HIPAA rule governing electronic health care transactions.

The deadline for compliance with the electronic transactions rule is Oct. 16, 2002 for all covered entities except small health plans, which by law had an additional year. Last year, in the Administrative Simplification Compliance Act, Congress authorized a one-year extension - to Oct. 16, 2003 - for those covered entities required to comply in 2002. To obtain the extension, a covered entity must submit a compliance plan on or before Oct. 15, 2002. Covered entities can use the model plan for this purpose.

A covered entity will be able to submit its extension plan electronically through the CMS Web site and CMS will provide an electronic confirmation of receipt of the plan. Covered entities also have the option of submitting its own version of an extension plan that provides equivalent information and can submit a plan on paper. Instructions for filing a plan are available on the Web site.

Health care providers that do not submit a compliance plan must comply with the HIPAA electronic transactions rule by October 16, 2002. Small health plans with less than $5 million in receipts already have until October 2003 to comply and do not need to submit a compliance plan.

Under the Administrative Simplification Compliance Act, health care plans and providers must submit information on their compliance activities, including budget, assessment of compliance concerns, whether a contractor or vendor might be used to help achieve compliance, and a schedule for testing to begin no later than April 16, 2003. Nebraska SNIP has developed two templates for the compliance projects. One template is a phase approach while the second is a task approach.

The model compliance plan, and instructions on how to complete it, is available at www.cms.hhs.gov/hipaa/hipaa2/ascaform.asp. Electronic submission capability is available on the Web site. The model compliance plan and instructions were published in the April 15, 2002 Federal Register.





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