5010 Deadline Four Days Away, Discretion Period or Not

It’s no surprise (unless you’ve been on the moon) that the new 5010 documentation standard becomes effective Jan. 1, 2012. Any relief offered by a Centers for Medicare & Medicaid Services (CMS) decision to impose a discretion period via contracted payers ending March 31st doesn’t let billers off the hook. Compliance for implementation remains January 1.

Here is what CMS is saying:

“Medicare FFS has experienced significant increases in 5010 production transactions during the last few months. Submitters have tested, but have not taken the step to move into production for 5010 and D.0. In addition, many submitters have not yet initiated testing with their Medicare administrative contractor (MAC). To ensure progress continues to be made, CMS is planning to take the following steps for submitters and receivers of Medicare Part B and durable medical equipment (DME) transactions (submitters and receivers of Medicare Part A transactions will follow the same action plan starting 30 days after Part B and DME).

  • In December 2011, submitters/receivers that have tested and been approved for 5010/D.0 will be notified that they have 30 days to cutover to the 5010/D.0 versions.
  • Submitters/receivers that have not yet tested will be notified in December 2011 that they must submit their transition plan and timeline to their MAC in 30 days.
  • MACs will notify submitters/receivers; and submitters/receivers have the responsibility to notify the providers they service.

“If a complaint is received by CMS after January 1, 2012, the entity against which the complaint has been filed will be evaluated to determine its level of compliance. An assessment will be made of the filed-against entity’s efforts to test and become compliant. OESS will take appropriate actions as permitted under the authority of the HIPAA enforcement rule, but will not assess any penalties and/or civil monetary penalties during this 90-day period.”

In other words: Failure after Jan. 1 to provide such information as physical addresses, nine-digit ZIP codes, National Drug Codes (NDC), and other specific information may not delay payment, but it may prompt enforcement down the road. Contact your payer and, if you haven’t done so, do a 5010 test.

Check out this part of the CMS website for the latest information about the 5010 standard and the discretion period. In addition to answering frequently asked questions, the federal website has compliance plans and templates for practices, facilities, and payers.

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