DEPARTMENT OF HEALTH & HUMAN SERVICES 
Centers for Medicare & Medicaid Services 
7500 Security Boulevard, Mail Stop S2-26-12 
Baltimore, Maryland 21244-1850 
Center for Medicaid and State Operations 
SMDL #02-015 
October 4, 2002 
Dear State Medicaid Director: 
This is an urgent reminder to all entities covered under the Health Insurance Portability 
and Accountability Act (HIPAA), and those associations whose memberships are 
comprised of covered entities, that October 15, 2002, is the deadline to submit a HIPAA 
Model Compliance Plan under the Administrative Simplification Compliance Act 
(ASCA). 
This Act extends the deadline for compliance with the HIPAA Electronic Health Care 
Transactions and Code Sets standards one year  to October 16, 2003  for all covered 
entities, other than small health plans, who submit a compliance plan.  Small plans 
already have until October 16, 2003.  Since you are a covered entity and may conceivably 
not be compliant with the HIPAA Electronic Health Care Transactions and Code Sets 
standards by October 16, 2002, you must file a compliance plan in order to obtain an 
extension if you have not already done so.  If you would like guidance on determining the 
extent to which you, your members or your business associates are covered entities 
please see our website at www.cms.hhs.gov/hipaa/hipaa2. 
In addition, this reminder is also to request that you contact your business associates who 
may be in a similar situation; i.e. need to file an application for the one-year extension. 
Business associates are defined as entities under contract with providers, state Medicaid 
agencies, and other covered entities (e.g., health plans, health care clearinghouses, health 
care providers) who transmit any health information in electronic form in connection with 
transactions for which the Secretary has adopted standards at 45 CFR Part 162.  Business 
associates who are not covered entities DO NOT have to submit a compliance plan. 
For further information on how to complete this compliance plan, refer to our website at 
http://www.cms.hhs.gov/hipaa/hipaa2/ASCAForm.asp.  I strongly encourage you to go to 
the website and submit this on-line compliance plan electronically, so we can provide an 
on-line confirmation number as acknowledgment of your extension.  Page 2  State Medicaid Director 
Please note the urgency of this request so that you and your memberships can comply 
with the requirements for requesting extensions of the October 15, 2002 deadline in a 
timely manner. 
Sincerely, 
/s/ 
Dennis G. Smith 
cc: 
CMS Regional Administrators

CMS Associate Regional Administrators

for Medicaid and State Operations

Lee Partridge

Director, Health Policy Unit

American Public Human Services Association

Joy Wilson

Director, Health Committee

National Conference of State Legislature

Matt Salo

Director of Health Legislation

National Governors Association

Brent Ewig

Senior Director, Access Policy

Association of State and Territorial Health Officials

Jim Frogue

Acting Director, Health and Human Services Task Force

American Legislative Exchange Council

Trudi Matthews

Senior Health Policy Analyst

Council of State Governments