This article was co-authored by Rachel H. Wilson, an associate at Pepper Hamilton. Pepper Hamilton LLP is a multi-practice law firm with more than 400 lawyers in ten offices. A specialist in healthcare, Steve is a frequent writer and speaker on healthcare information management and technology issues. Steve's responses offer information that is general in nature and should not be relied upon as legal advice. Only your attorney is qualified to evaluate your specific situation and provide you with customized advice.
Vendors pay an annual fee to submit transactions for certification.
Certification is given on a per transaction type basis and only one transaction must be successful prior to certification. In other words, they will rely on third parties, rather than themselves, to ensure their compliance. Clearly, these providers should closely monitor the progress of these external groups. Many others are awaiting vendor responses. Similarly, while many provider respondents listed difficulty in achieving compliance within regulatory time frames as a prime concern, these were often the same organizations who are waiting until final rules are published before taking action.