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Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 requires electronic reporting of workers' comp data. But the IAIABC panel notes there are technical challenges that should be addressed.

"The CMS Task Force draws on the IAIABC's expertise in developing and maintaining national electronic data interchange standards as it interfaces with CMS to address issues, monitor their status, and report results back to its members," said a letter to CMS officials. "The Task Force has met regularly and has openly shared its work products used to develop this statement with all interested parties."

The idea of the task force is not to merely complain to CMS but to have a cooperative relationship by offering potential solutions. "The task force includes people who have done EDI for many years," said Catherine S. Dominguez, chair of the task force and director of MRRS Products for Mitchell Workers' Compensation Solutions. "They have a lot of good insight into what's been done. We'd like to help CMS and make sure the impact is minimal, for whatever they do decide to do, on the workers' comp community."

Members of the task force say they've been encouraged by CMS' responses to some of the industry concerns that have been raised to date. Recently, the panel identified several issues that still need to be addressed.

"These were the top four concerns we've been seeing that make it difficult for us to streamline our operations," Dominguez said.

Among the four challenges to responsible reporting entities is "RREs' inability to effectively automate the error correction process, including the problem that CMS' error messages are too broad."

Recognizing that modifying error messages would be a "complex task," the panel is offering to help. The IAIABC's Systems Committee, which has developed error messages for the IAIABC EDI standards, is sharing its experience with the task force to craft a solution that could be utilized without affecting constituents that don't want to change.

Other problems and suggested solutions include:

• CMS' use of e-mail to communicate with responsible reporting entities on data-related issues, which make it "extremely difficult, if not impossible, to automate any type of recovery or correction process," according to the letter. Also, the messages are sent only to the responsible reporting entity's account manager, who may be unavailable to access the message for days or weeks.
  "They said they've heard this before," Dominguez said. "They are taking it under advisement and truly do understand the difficulties being faced." The task force has suggested expanding the notifications to all account representatives and ultimately implementing a functional acknowledgment process to allow more complete EDI and eliminate the need for a layer of human intervention.
• Bandwidth capacity, accessibility, and loss of files from the CMS FTP server. A web service provided as an alternate "is not consistently reliable and it does not allow the efficiency of batch processing," the letter states. Dominguez said there have been some improvements and there may be more efforts to alleviate some of the missing file problems in the next couple of months.
• CMS' practice of suspending claim input file processing when 5 percent or more of the claims are delete transactions. The panel recommends raising the threshold to allow responsible reporting entities to report delete transactions as a normal course of business versus the necessity to manually intervene. "That issue they said is working wonderfully in group heath," Dominguez said. "They will continue to look at it, but right now it continues to stand."

Read more at the WorkersComp Forum homepage.

May 19, 2011

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