What’s Good for the Dentist is Good for the Medical Doctor as Well
By Robert Patrick

Robert Patrick is president of dental at Vyne of Dunwoody, GA.

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Medical professionals might be tired of the endless requirements of mailing x-rays or other documentation to the insurance company every time they file a claim. Some of them might simply want the ability to add their supporting documentation to claims electronically for easier adjudication.

While medical professionals continue to wait for developments and guidance related to the use of electronic attachment solutions and technologies, their dental colleague counterparts have no such obstacles. Even though there’s no formalized standardization from an organization like the Center for Medicare and Medicaid Services (CMS) for dental, there is a range of solutions that have permeated the sector and enjoy robust use by many thousands of dental practices. Why the disparity?

The simplest reason is that the solutions are readily available in the dental sector, Their use has been embraced despite there being little formal regulation or guidance related to submitting electronic attachments. For example, as long as the solutions are compliant with HIPAA, their use is fair game. Per recent reporting, some on the medical side of healthcare are waiting for a push toward standardization in the way electronic attachments are sent before moving forward with similar solutions.

According to reporting by MedPage Today, Robert Tennant, director of health information technology policy at the Medical Group Management Association — a trade group that represents medical practices — said that HIPAA includes a directive for the federal government to develop standards for electronic attachments. But the HIPAA provision still is not seeing traction or light of day. Even when the Affordable Care Act (ACA) was passed in 2010, it included a provision requiring the federal government to issue a final rule on standardizing electronic attachments, and a deadline of January 1, 2014, for doing so, but nothing yet.

The delay, Tennant speculates, might relate to how CMS can address “solicited” versus “unsolicited” attachments. Maybe the use of a secure attachment protocol or portal for data submission could eliminate this concern. For example, with dental electronic attachment solutions, providers can simply upload their supporting documentation via HIPAA-compliant software services. The respective payer is then notified that attachments are available for claim processing. No muss, no fuss. 

While there’s no requirement or mandate for dental providers to submit attachments, just like there is not one for medical doctors, dental providers are leading the way having embraced the move to electronic attachments years ago, unlike their medical colleagues. Any care professional can (?) make use of the technology, and there is a market on the medical side of the fence, so why the delay in adoption?

One potential issue is that some believe submitting attachments to be “a fairly complex transaction” for health plans to implement. “Since CMS also controls Medicare and Medicaid, they would be required by law to implement this standard, and maybe there is some pushback in terms of the cost to implement this transaction,” said Tennant in the report.

Is regulation on electronic attachments forthcoming for medical providers? The federal electronic attachment conversation continues and was included in the federal government’s unified agenda — a plan of action issued by the Office of Management and Budget — that might not be considered until later this year.

According to regulatory guidance, the electronic attachments rule must contain data formats to be used for the attachments. In 2016, the National Committee for Vital and Health Statistics, a public group that advises the Health and Human Services (HHS) secretary on health data issues, laid out its recommendations for electronic attachments, including suggested formats, in a letter to then-HHS Secretary Sylvia Burwell:

  • For the request for attachments, the group recommended using the ASC X12 format
  • For the response with a submission of attachment, the HL7 format is recommended
  • For the acknowledgement of the response, the ASC X12 format is recommended

For reference, the Accredited Standards Committee X12 (ASC X12) provides standards that can be used for nearly all facets of business-to-business operations conducted electronically. The committee aims to:

  • Develop high-quality e-commerce standards that are responsive to the needs of the standards user
  • Collaborate with other existing standards to make the standards developed more interoperable
  • Avoid any conflict, confusion, and duplication of effort
  • Publish and promote the standards along with their education
  • Drive the implementation and adoption of the standards developed by the committee

Health Level 7, or HL7, refers to a set of international standards for transfer of clinical and administrative data between software applications used by various healthcare providers. These standards focus on the application layer, which is “layer 7” in the OSI model.

The group also recommended that HHS define attachments as the “supplemental documentation needed about a patient(s) to support a specific healthcare-related event (such as a claim, prior authorization, referrals, and others) using a standardized format.”

One thought is that with such guidance and with the backing of CMS, there might be a reduced “provider burden.”

What about the payers? Why not a push by payers for standardized operations? Why don’t payers and providers just decide on standards and implement them without any government help? This hasn’t happened because payers argue that it will cost too much money to implement; no one is going to bother if vendors don’t create products for the providers. Some vendors, of course, are not willing to produce a solution for such without payer’s backing.

In medical care, it seems that everybody’s waiting for somebody else, and no one will do it until the government issues the standard. Perhaps these arguments are valid for physicians, but for dentists, this foundation already is laid. Perhaps infrastructure is the real problem for medical providers. Nevertheless, the technological capabilities exist and have for many years.

If electronic attachments were implemented in medical care, the result could be savings for both health plans and providers, according to the Council for Affordable Quality Healthcare (CAQH), a non-profit alliance of health plans and other organizations whose goal is to streamline healthcare administration. The 2017 CAQH Index report found that only six percent of medical attachments were submitted electronically that year, but the report also found that providers could it save 51 cents per claim – 30 percent of their current cost — if electronic submission were employed, while health plans could save $1.64 per claim, a 94 percent savings.

CAQH launched a project under its Committee on Operating Rules for Information Exchange (CORE) division — a group of about 130 organizations developing operating rules for healthcare administration — to scan and discover where the healthcare industry stands in relation to electronic attachments, including use of a standard format. The organization is examining the varying types of use cases for documentation and the products available in the marketplace to support an automated approach to move the industry forward.

While the number of electronic attachments exchanged is quite small in volume, at least for medical providers, there is a clear path in place that can be executed with or without the support of an organization like CMS or others, as we have seen on the dental side of the house. While doctors may have been waiting for some guidance since HIPAA’s creation in 1996, dentists have been successfully using electronic attachment solutions since at least 1997, and with great results.

Thus, if more than 60 percent of the dentists in America who need to send supporting documentation to payers to get paid for their service are doing so electronically, why can’t the medical professionals of America do the same? America’s dental payers have agreed to participate in electronic attachments while America’s medical payers seem to be waiting for a mandate.