Believing that if passed, legislation to delay HIPAA may in effect kill it, the Coalition for Health Information Policy (CHIP) has sent a letter to key Senate Democrats asking them to oppose legislation and other efforts to delay the Transactions and Code Sets rule.

The full text of the letter follows:

June 18, 2001

The Honorable Charles E. Grassley
United States Senate
Washington, DC 20510

Dear Senator Grassley:

The Coalition for Health Information Policy (CHIP) represents a broad array of professionals and organizations involved in the development, use, management, and security of health information systems, across all sectors of the healthcare industry. CHIP strongly supports the timely implementation of the health information standards called for by Sec. 262 and Sec. 264 of the Health Insurance Portability and Accountability Act (HIPAA). We write to you today to express our opposition to proposals that would delay the compliance deadline for the Transaction Standards regulation, which is scheduled to be fully effective in October 2002. Specifically, we ask that you not support S. 836, which was introduced by Senator Craig last month, either as a stand-alone bill or as part of some larger legislation.

The membership of the Coalition for Health Information Policy (CHIP) includes: the American Health Information Management Association (AHIMA) - 41,000 professionals who manage health records; the American Medical Informatics Association (AMIA) - 3,700 information systems developers and academic physicians; the Center for Healthcare Information Management (CHIM) - 140 healthcare information technology companies; and the Healthcare Information and Management Systems Society (HIMSS) - with more than 43 chapters and 12,000 members who are healthcare professionals working in healthcare organizations worldwide. Members of our associations facilitate the control, flow, and storage of billions of pieces of health information each day. We are strongly committed to protecting the standardization, accuracy, security and privacy of that information, and at the same time cognizant of the legitimate and appropriate uses of health data to improve both individual care and the health of our nation as a whole.

The Health Insurance Portability and Accountability Act (HIPAA) called for the development and implementation of a comprehensive set of health information standards in order to meet the goals of administrative simplification. These included transaction standards and code sets for the electronic exchange of health information, as well as regulations intended to protect the security and privacy of individually identifiable health information. As you know, the Department of Health and Human Services has worked closely with the healthcare industry for more than five years to develop the HIPAA standards. While the several rules that ultimately will govern the treatment of health information are interrelated, CHIP does not believe that they must be implemented as a package. Rather, in our view the Transaction and Code Set standards represent a major and essential first step toward the standardized exchange of health information and data definitions, that can be planned for within the announced implementation timeline, and modified successively as the remaining transaction-related HIPAA rules are released.

As noted above, the associations of CHIP are very much concerned with the potential impact of S. 836. Not only would the bill unnecessarily delay implementation of the transaction and Code Set standards, but its open-ended language could frustrate the implementation of other HIPAA rules and prevent us from reaching the goals of administrative simplification: improving the quality of health care, increasing access to health services, and decreasing costs.

HIPAA provides for additions and modifications to any standards adopted under its administrative simplification provisions, including the Transaction Standards, and the Department of Health and Human Services in collaboration with private standard setting organizations has put into place a series of processes under which covered entities
can request necessary changes and clarifications. In regard to the Transaction Standards rule, CHIP is confident that these mechanisms, when combined with genuine efforts to move toward compliance on the part of covered entities, will allow implementation of the Transaction Standards by October 2002 as scheduled. Further, we believe that HIPAA allows HHS the necessary flexibility to provide guidance to covered entities that are making a good faith effort to implement the standards and even to permit additional time to reach full compliance with the rule.

Thank you for considering our views regarding the inadvisability of further delays of the HIPAA administrative simplification rules. Members of our associations would be happy to brief your staff on the technical and operational implementation of the Transaction Standards, and such related issues as the need to resolve the use of local codes by payers, including the Medicare and Medicaid programs in particular. We encourage you to contact our Washington representative, Doug Peddicord, at (202) 543-7460 to arrange such a meeting.

Sincerely,