WEDI SNIP has concluded that the mandated timeframes will not be met unless we can find a more efficient way to conduct these implementations. This may be a topic for another time. The number one concern that the WEDI SNIP Business Issues work group has identified is in the interpretation of the regulations. Although there needs to be a place to take interpretation issues for quick resolution, such a formal mechanism does not exist today. Many times we simply ask someone from HCFA or HHS who is working in the work group for an answer.
Official answers take more time.
We believe the number of issues will begin to expand rapidly as organizations begin to analyze their requirements and determine their data gaps and questions. Specific issues where clarification is needed include the role of clearinghouses, coordination of benefits, permissible implementations of direct data entry solutions, and more. I have included an electronic copy of this draft white paper with my testimony. This problem is reviewed in terms of the business issues created by this change. SNIP proposes some suggestions on how organizations might proceed with their implementation.