5010 – Much Ado about Nothing?

It seems like not a day goes by in healthcare without some gloomy prediction about the changes lurking on the horizon. The one causing the most stir at the moment is 5010. To understand “5010,” we first need to take a stroll down memory lane to when HIPAA was enacted. Aside from the privacy and security changes associated with this regulation, one of HIPAA’s first goals was that of “administrative simplification” oriented toward adopting national standards for electronic health care transactions, such as claims. The version of the transactions named in HIPAA is Version 004010, or “4010.” Business changes, including the impending transition to ICD-10-CM, necessitated a revision of these standards and Version 005010 – or “5010” – was born.

Since ICD-10 implementation is still about two years away, many providers erroneously believe 5010 is similarly a future consideration. However, 5010 will impact providers in January of 2012 in some important ways, such as:

  •  Zip code: In 5010, providers must submit a nine-digit zip code when reporting billing provider and service facility locations.
  • Billing provider address: 5010 guidelines require that the billing provider be listed as a physical address, and not a P.O. box or lock box.
  • Anesthesia minutes: In 5010, anesthesia services must be reported in minutes; providers will no longer have the flexibility of reporting anesthesia in units, which exists in 4010.

So although these issues may seem primarily software-related or technical, they will impact provider operations if billing information is incomplete or erroneous. This could also have serious payment repercussions if reimbursement is delayed due to billing challenges. It is advisable that providers:

  • Check the CMS website for the Approved Vendor List to assess their vendor’s readiness with 5010 transactions.
  • Educate all staff on the 5010 changes and revise operational processes to ensure the required information is documented and submitted to appropriate entities.
  • Solidify lines of credit as a safety net during the 5010 and eventual ICD-10 transition which are expected to disrupt productivity and hence, cash flow.

Historically, CMS has been known to publish deadlines prematurely only to rescind them and sometimes considerably delay implementation (e.g., PECOS). However, Medicare fee-for-service (FFS) transactions must be submitted in the 5010 format beginning on January 1, 2012. CMS has created a 90-day discretionary enforcement period which means that no fines will be assessed against non-compliant providers for a short time.

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