Frequently Asked Questions - VIII. CAQH CORE 155: Batch Response Time Rule
- The maximum response time for the availability of the ASC X12 Implementation Acknowledgement (999) is one hour as specified in CAQH CORE 155: Batch Response Time Rule. What is the maximum response time for HTTP message after a file is dropped off?
- If an X12 270 is received in a batch, does the X12 271 have to be returned in a batch?
- Do the time frames still apply if it is an especially large batch? Do the CAQH CORE Rules define the batch size?
- How should the X12 270/271 transactions be tracked throughout a system/application to demonstrate conformance with the response time requirements specified in the CAQH CORE 155 Rule?
The CAQH CORE Rule does not address this issue. The batch response time rule only requires that a health plan have the batch of responses available by 7:00 AM the next business day following a submission of inquiries by 9:00 PM ET the previous business day. Therefore, the CAQH CORE 155 Rule does not specify whether or not the batch of X12 271 responses must match exactly the batch of X12 270 inquiries.
The CAQH CORE 155 Rule does not define batch size. Section 6 of the CAQH CORE 270: Connectivity Rule Version 2.2.0 defines a large batch file (payload) as "A single submission of a message payload that contains more than one X12 Interchange, each of which may contain one or more Functional Groups, each of which may contain one or more X12 transaction sets."
The CAQH CORE Response Time Rules (CAQH CORE 155 & 156 Rules) require HIPAA covered entities to capture, log, audit, match, and report the date, time, and control numbers from their own internal systems, and corresponding data received from their trading partners. The auditing requirement is included so that each entity will have the log of data to be used to resolve any issues or concerns. For the 20-second maximum real time response requirement, this log could also be used to identify where a bottleneck may be occurring.
Section 4.3.4 of the CAQH CORE 270: Connectivity Rule also specifies that, to comply with CAQH CORE 155 and 156, message receivers will be required to track the times of any received inbound messages, and respond with the outbound message for that payload ID. Additionally, message senders must include the CORE Envelope Metadata element Time Stamp (as specified in the CAQH CORE 270 Rule, Section 4.1.2). Other data may be required for auditing purposes; however, this data can be determined by each entity. CAQH CORE recommends that, in order to uniquely identify an X12 transmission, entities store the ISA06, ISA08, ISA13, GS02, GS03, GS06, ST02, TRN02, and if sent in the transaction, the BHT03.
The audit log requirement was purposefully specified at a high level in each rule to enable each entity along the transaction pathway to design and develop its own process for audit handling. Additionally, the rules do not specify how long an entity is to maintain the data for auditing purposes.
(See “How Should entities track the X12 270/271 and/or X12 276/277 transactions when using another connectivity method, as permitted by the CAQH CORE Connectivity Safe Harbor?” for guidance on tracking when using a non-CAQH CORE Connectivity method.)