MGMA Comments on Attachments Rule
(January 25, 2006)

The federal government should stagger compliance deadlines for implementing the HIPAA claims attachment standard, with providers having 12 months longer than clearinghouses and payers, according to the Medical Group Management Association.

MGMA, in a Jan. 23 comment letter to the Centers for Medicare and Medicaid Services, notes clearinghouses, physician software vendors and insurers need to be ready to support standardized electronic attachments before providers can start the testing process.

The proposed rule sets a compliance date for covered entities--clearinghouses, providers and payers--of 24 months after the effective date of a final rule. Englewood, Colo.-based MGMA advocates a 36-month compliance window for providers to give a "designated" 12-month testing period.

"MGMA believes that the timeframe outlined is not adequate for the implementation of the claims attachment standard," according to the comment letter. "In order to transition to this new standard, like the other HIPAA transaction and code set standards, providers will be forced to rely on their software partners, the majority of which are not covered entities."

Other recommendations from the association include:

  • The Centers for Medicare and Medicaid Services should develop and make available crosswalks between the ICD, CPT and LOINC code sets used in the attachments standard. "Providers will be significantly challenged by LOINC," the comment letter states. "The HL7 'languages' are not commonly used by physician practices, especially smaller ones. CMS needs to identify a process to educate providers on how to access and utilize LOINC codes."
  • While the government proposed six specific attachment types, MGMA believes more are needed. "These may include such types as durable medical equipment, medical necessity, sterilization consent forms, Medicaid spend-down, secondary payer questionnaire, and home health."
  • The government should consider creation of "technology savings accounts" to assist providers in implementing information technology. "TSAs could enable group practices to pay for current expenses and save for future qualified health information technology expenses on a tax-free basis," according to the comment letter. "Unspent account balances would accumulate and accrue interest."

Full text of the comment letter is available at


Posted to HIPAAcomply 1/25/06