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As a Pharmacy Benefits Management (PBM) company, NEChealth Networks' and our partner MedImpact's line of business is specific to the pharmacy industry. Since we transmit and process Protected Health Information (PHI) on behalf of our clients, many of which are Covered Entities (CEs), we are defined by HIPAA as a Business Associate (BA). BAs are Non-Covered Entities, and after consulting with officials at the Department of Health and Human Services (DHHS), it has been determined that not all HIPAA Standards apply to our line of business. However, we will take all necessary steps outlined in the Privacy and Security Final Rules to safeguard PHI.
NEChealth and MedImpact has developed and maintained a comprehensive HIPAA Implementation Plan for each of the HIPAA Final Rules. We have established vital contacts at DHHS, The Office of Civil Rights (OCR), and The Centers for Medicare & Medicaid Services (CMS) for continued guidance, and have attended numerous government sponsored conferences/events to stay up-to-date with the latest developments. NEChealth and MedImpact will also continue to participate and monitor the vital contributions of the WEDI/SNIP HIPAA Task Groups to ensure that our HIPAA initiatives are in-sync with the health care industry expectations.
NEChealth and MedImpact have the capability to accept and process the HIPAA-mandated NCPDP Telecommunications V5.1 Standard for pharmacy drug claims using the HIPAA-mandated NDC codes. We also have the capability to transmit the ANSI ASC X12N 835, V4010A Standard for Remittance Advice. Both the NCPDP and X12 standards are available to pharmacies and their vendors. As our contingency plan per the July 24, 2003 HHS Guidance on Compliance, we will continue to accept the NCPDP Telecommunications Standard V3.2, as well as continue to accept paper EOBs, and transmit EOBs in our proprietary formats until HHS terminates these compliance provisions (other than paper). We encourage all pharmacies and their vendors who are using non-HIPAA transactions after the October 16, 2003 Compliance Date to contact us so the NCPDP Telecommunications V5.1 and X12 835 standards are established.
We understand that HIPAA is a life cycle model/project, and in the future, DHHS will continue to publish more Final Rules. When this happens, we will evaluate and implement our BA obligations for each Final Rule and continue to apply for, pass, and maintain, all applicable certification/accreditation to ensure that our products, services, and systems are designed, programmed, and maintained according to the HIPAA Final Rules-thereby ensuring that we have a strong foundation to build on as our organization and business initiatives continue to GROW. Concurrently, we will continue to work with our valued business partners to develop and maintain our HIPAA initiative so we will always remain in perpetual compliance. If you have any questions or comments, please feel free to contact us at HIPAA@nechealth.com.
MedImpact Healthcare Systems, Inc., located at 10680 Treena St., 5th floor, San Diego, CA 92131 is a business partner and exclusive processor of National Extended Care Networks, LLC.
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