The regulations establish standards for the following transactions. The transaction standards for pharmacy are the National Council for Prescription Drug Programs' Telecommunications Standard and Batch Transaction Standard. For other transactions, the standards are the ASC X12N standards published by the Washington Publishing Company. Private arrangements among covered entities that would have the effect of changing or supplementing the standards will be prohibited. Covered entities, however, will be permitted to use health care clearinghouses or other intermediaries to conduct transactions, and clearinghouses will be permitted to receive and transmit nonstandard transactions when acting on behalf of other covered entities.
Health plans are subject to additional standards.
They will be required to conduct electronic claims transactions in standard format with any person wishing to do so. This entails an obligation both to accept standard transactions and to process them promptly. Other standards have been proposed to protect the privacy and security of electronic data and to establish national identifiers, but they remain under review. The proposed privacy regulations, in particular, have prompted a record number of public comments. Interestingly, HHS states in the accompanying comment section that these regulations were developed in conjunction with the development of the privacy standards.