Phase IV CAQH CORE Operating Rules

III. CAQH CORE 452: Health Care Services Review – Request for Review and Response (278) Infrastructure Rule

NOTE: Implementation of the Phase IV CAQH CORE Operating Rules is currently voluntary. HHS will determine if the Phase IV CAQH CORE Operating Rules will be included in any regulatory mandates. The Phase IV FAQs are for use by entities completing voluntary implementation of the operating rules and/or pursuing Phase IV CORE Certification which will be available in Fall 2016. 

 

  1. If an ASC X12N v5010 278 Request is received in a batch, does the ASC X12N v5010 278 Response have to be returned in a batch?
  2. Currently my organization’s EDI system returns a positive ASC X12C v5010 999 Acknowledgment reporting acceptance of the ASC X12N v5010 278 submitted in Real Time Processing Mode. If the Functional Group is rejected, must my system be changed to comply with the Real Time requirements?
  3. Do the time frames for the Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule still apply if it is an especially large batch? Do the CAQH CORE Operating Rules define the batch size?
  4. Why measure response time conformance based on the percentage of responses returned within a specified timeframe rather than average response time?
  5. Is there a standard reporting form for the conformance reporting?
  6. If a CORE-certified entity is communicating with a non-CORE-certified entity, does the CORE-certified entity have to respond within the specified response time window?
  7. Can a clearinghouse or vendor act on behalf of a health plan for providing ASC X12N v5010 278 Request real time Reponses?
  8. What are the Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule requirements for entities to support real time and/or batch processing?
  9. Are there any requirements regarding how often ASC X12N v5010 278 Request and Response transactions should be submitted? (e.g., Do CAQH CORE Operating Rules either support or exclude a provider or vendor from sending daily batches of ASC X12N v5010 278 Request and Response transactions?)
  10. Currently my organization’s EDI system returns a positive ASC X12C v5010 999 Acknowledgment reporting acceptance of the ASC X12N v5010 278. If the Functional Group is rejected, must my system be changed to comply with the Batch Acknowledgement Requirements?
  11. My organization’s EDI system was developed in-house and does not currently support the TA1. However, our system does support the ASC X12C v5010 999 Acknowledgment for rejected functional groups. Is this conformant under the Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule requirements?
  12. If my organization’s system is not changed to return the ASC X12C v5010 999 Acknowledgment, can my organization become CORE-certified?
  13. The TA1 Interchange Acknowledgment is described in the HIPAA Implementation Guide Appendix B: EDI Control Director. Do the Phase IV CAQH CORE Operating Rules require its use?
  14. Do the CAQH CORE 452 Rule Real Time Acknowledgement Requirements require that my organization’s system must always return both of these types of Acknowledgements: ASC X12C v5010 999 Acknowledgment and the ASC X12N v5010 278 Response?
  15. Is an acknowledgement necessary if the user sends prior authorization data in a proprietary (not an ASC X12 278) format in a real time mode?
  16. Are all Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule requirements with regard to acknowledgement only applicable to scenarios where my organization receives data in an ASC X12N v5010 278 format?
  17. Does my organization have to send back either an ASC X12C v5010 999 Acknowledgment or an ASC X12N v5010 278 Response to a submitted prior authorization if my system is down?
  18. My organization includes system availability schedules in our Companion Guide. Does this satisfy the CAQH CORE Operating Rule requirements for system availability reporting?
  19. Why was the Master Companion Guide Template created?
  20. Does the Phase IV CAQH CORE 452 Rule require HIPAA-covered entities to publish a Companion Guide if they do not currently do so?
  21. Does the Phase IV CAQH CORE 452 Rule require health plans to request approval from ASC X12 prior to publication of their CORE-conformant Companion Guide?
  22. Can I combine multiple transaction sets in a single companion guide?
  23. Does this rule apply if my organization does not conduct the ASC X12 v5010 278 transaction?
  24. Why is there a variability in elapsed times for returning acknowledgements or responses between the four Phase IV CAQH CORE Infrastructure Rules?
1. If an ASC X12N v5010 278 Request is received in a batch, does the ASC X12N v5010 278 Response have to be returned in a batch?

The rule requirement addressing response time when an ASC X12N v5010 278 request is submitted in batch processing mode by 9:00 pm ET on a business day only requires that a health plan have the batch of responses available by 7:00 am ET by the third business day following submission of an ASC X12N v5010 278 Request. The CAQH CORE 452 Rule does not specify whether or not the batch of responses must match exactly the batch of ASC X12N v5010 278 requests.

2. Currently my organization’s EDI system returns a positive ASC X12C v5010 999 Acknowledgment reporting acceptance of the ASC X12N v5010 278 submitted in Real Time Processing Mode. If the Functional Group is rejected, must my system be changed to comply with the Real Time requirements?

Yes. Per the Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule, an ASC X12C v5010 999 Acknowledgement must only be returned when a Functional Group or Transaction Set of an ASC X12N v5010 278 request is submitted in Real Time Processing Mode is rejected.

Therefore, the submitter of an ASC X12N v5010 278 Request in Real Time will receive only one of two possible responses from the HIPAA-covered health plan or its agent: an ASC X12C v5010 999 Acknowledgment or an ASC X12N v5010 278 Response.

3. Do the time frames for the Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule still apply if it is an especially large batch? Do the CAQH CORE Operating Rules define the batch size?

The Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule and the CAQH CORE 470 Connectivity Rule do not define batch size. The maximum size of a batch file that is accepted by a Server is outside the scope of the rule; the implementer of a Server may publish its file size limit, if any, in its Connectivity Companion Guide. Therefore, the response time frame for all acknowledgements specified when an ASC X12N v5010 278 request claim is submitted in Batch Processing Mode applies to all batches. 

4. Why measure response time conformance based on the percentage of responses returned within a specified timeframe rather than average response time?

Averages can be skewed by outlier responses. The percentage of responses returned within the specified timeframe gives a better indication of the entity’s capabilities.

5. Is there a standard reporting form for the conformance reporting?

No. The CAQH CORE Operating Rule does not mandate a particular form.

6. If a CORE-certified entity is communicating with a non-CORE-certified entity, does the CORE-certified entity have to respond within the specified response time window?

Yes. An entity, e.g., a provider, does not have to be certified by CAQH CORE to interact with a CORE-certified entity, e.g., a health plan, under the CAQH CORE Operating Rules.

7. Can a clearinghouse or vendor act on behalf of a health plan for providing ASC X12N v5010 278 Request real time Reponses?

Yes. The Phase IV CAQH CORE Health Care Services Review – Request for Review and Response (278) Infrastructure Rule defines the specific requirements that HIPAA-covered health plans or their agents and HIPAA-covered providers or their agents must satisfy. In this context, an agent is “one who agrees and is authorized to act on behalf of another, a principal, to legally bind an individual in particular business transactions with third parties pursuant to an agency relationship.” (Source: West's Encyclopedia of American Law, edition 2, Copyright 2008 The Gale Group, Inc. All rights reserved).

Importantly, the response that a HIPAA-covered health plan or its agent returns is dependent on whether the ASC X12N v5010 278 Request submitted in Real Time processing mode is rejected or accepted.

A HIPAA-covered health plan or its agent must return:

  • An ASC X12C v5010 999 Acknowledgement to indicate that a Functional Group(s) or Transaction Set(s) is rejected.

A HIPAA-covered health plan or its agent must not return:

  • An ASC X12C v5010 999 Acknowledgement to indicate that a Functional Group(s) or Transaction Set(s) is accepted or accepted with errors.

Therefore, the submitter of an ASC X12N v5010 278 Request in Real Time processing mode will receive only one of two possible responses from the HIPAA-covered health plan or its agent: an ASC X12C v5010 999 Acknowledgement or an ASC X12N v5010 278 Response.

8. What are the Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule requirements for entities to support real time and/or batch processing?

The Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule requires that a HIPAA-covered health plan or its agent must implement the server requirements for either Real Time Processing Mode OR Batch Processing Mode for the ASC X12N v5010 278 Request and Response transactions as specified in the Phase IV CAQH CORE 470 Connectivity Rule. Optionally, a HIPAA-covered health plan or its agent may elect to implement both Real Time and Batch Processing Modes.

A HIPAA-covered health plan or its agent conducting the ASC X12N v5010 278 Request and Response transactions is required to conform to the processing mode requirements specified in this section regardless of any other connectivity modes and methods used between trading partners.  

9. Are there any requirements regarding how often ASC X12N v5010 278 Request and Response transactions should be submitted? (e.g., Do CAQH CORE Operating Rules either support or exclude a provider or vendor from sending daily batches of ASC X12N v5010 278 Request and Response transactions?)

No. The Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule does not address the frequency of submission of ASC X12N v5010 278 Request and Response transactions in batch processing mode.  

10. Currently my organization’s EDI system returns a positive ASC X12C v5010 999 Acknowledgment reporting acceptance of the ASC X12N v5010 278. If the Functional Group is rejected, must my system be changed to comply with the Batch Acknowledgement Requirements?

Yes. The Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule requires that the HIPAA-covered health plan or its agent must always return an ASC X12C v5010 999 Acknowledgment for all Functional Groups of an ASC X12N v5010 278 Request, whether or not the Functional Group is rejected. This requirement allows the provider to know within a reasonable timeframe if the submitted batch of inquiries was accepted by the health plan and will be processed. Likewise, the rule also requires that the provider must always return an ASC X12C v5010 999 Acknowledgment for all Functional Groups of an ASC X12N v5010 278 Response, whether or not the Functional Group is rejected, thereby allowing timely resolution of any issues. 

Additional information on the return of an ASC X12C v5010 999 Acknowledgment by a HIPAA-covered entity or its agent can be found in Section 4.7.1 of the Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule

11. My organization’s EDI system was developed in-house and does not currently support the TA1. However, our system does support the ASC X12C v5010 999 Acknowledgment for rejected functional groups. Is this conformant under the Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule requirements?

Yes. Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule requirements address only the ASC X12C v5010 999 Acknowledgment; therefore your organization’s system must be able to return an ASC X12C v5010 999 Acknowledgment for all functional groups. If it is unable to do so, your organization will need to remediate the system to be in conformance with the CAQH CORE Rule in order to become CORE-certified.

12. If my organization’s system is not changed to return the ASC X12C v5010 999 Acknowledgment, can my organization become CORE-certified?

Your organization must successfully complete all of the required certification test scripts required by the Phase IV CAQH CORE Certification Test Suite to become CORE-certified. The test scripts for the Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule will test for your system’s capabilities to return the ASC X12C v5010 999 Acknowledgment.  

13. The TA1 Interchange Acknowledgment is described in the HIPAA Implementation Guide Appendix B: EDI Control Director. Do the Phase IV CAQH CORE Operating Rules require its use?

No. The Phase IV CAQH CORE Operating Rules do not address the use of the ASC X12 Interchange Acknowledgement TA1.

14. Do the CAQH CORE 452 Rule Real Time Acknowledgement Requirements require that my organization’s system must always return both of these types of Acknowledgements: ASC X12C v5010 999 Acknowledgment and the ASC X12N v5010 278 Response?

No. When an ASC X12N 278 Request is submitted in Real Time a HIPAA-covered health plan or its agent must only return an ASC X12C v5010 999 Acknowledgement to indicate that the Functional Group or Transaction Set is rejected.

A HIPAA-covered health plan or its agent must not return an ASC X12C v5010 999 Acknowledgement to indicate that a Functional Group or Transaction Set is accepted or accepted with errors.

Therefore, the submitter of an ASC X12N v5010 278 Request in Real Time will receive only one response from the HIPAA-covered health plan or its agent: an ASC X12C v5010 999 Acknowledgement or an ASC X12N v5010 278 Response. Thus, your organization’s system must return only one of these transactions, depending on the processing results, not both.

15. Is an acknowledgement necessary if the user sends prior authorization data in a proprietary (not an ASC X12 278) format in a real time mode?

Good business practices for electronic message exchange encourage all senders and receivers to appropriately acknowledge receipt and both acceptance/rejection and errors found in any message. Accordingly, the Phase IV CAQH CORE Rules are focused on the conduct of the HIPAA-named ASC X12 transaction sets and on the ASC X12 standards as well. Thus, the Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule only addresses the use of the ASC X12C v5010 999 Acknowledgment and when to use it when conducting the ASC X12N v5010 278 transaction sets. Additionally, in order to become CORE-certified, an entity is required to attest to its compliance with HIPAA, which requires the use of the appropriate ASC X12 implementation guides.

16. Are all Phase IV CAQH CORE 452 Health Care Services Review - Request for Review and Response (278) Infrastructure Rule requirements with regard to acknowledgement only applicable to scenarios where my organization receives data in an ASC X12N v5010 278 format?

Yes. Good business practices for electronic message exchange encourage all senders and receivers to appropriately acknowledge receipt and both acceptance/rejection and errors found in any message. Accordingly, the Phase IV CAQH CORE Rules are focused on the conduct of the HIPAA-named ASC X12 transaction sets and on the ASC X12 standards as well. Thus, the CAQH CORE 452 Rule only addresses the use of the ASC X12C v5010 999 Acknowledgment and when to use it when conducting the ASC X12N v5010 278 transaction sets. Additionally, in order to become CORE-certified, an entity is required to attest to its compliance with HIPAA, which requires the use of the appropriate ASC X12 implementation guides.

17. Does my organization have to send back either an ASC X12C v5010 999 Acknowledgment or an ASC X12N v5010 278 Response to a submitted prior authorization if my system is down?

As long as your prior authorization system is in conformance with the CAQH CORE System Availability Rule, then it is not required to send back a either an ASC X12C v5010 999 Acknowledgment or an ASC X12N v5010 278 Response, either in real time or batch when your system is down. When your system is back up such acknowledgements should be made available to the submitter.

18. My organization includes system availability schedules in our Companion Guide. Does this satisfy the CAQH CORE Operating Rule requirements for system availability reporting?

Yes, HIPAA-covered health plans (or information sources), clearinghouses/switches or other intermediaries must publish their regularly scheduled system downtime in an appropriate manner (e.g., on websites or in Companion Guides). This allows the healthcare provider to better manage staffing levels. Additionally, the CAQH CORE Operating Rule outlines requirements for reporting/publishing non-routine downtimes and unscheduled/emergency downtimes.

19. Why was the Master Companion Guide Template created?

For many years health plans independently created companion guides that often varied in format and structure. Such variance can be confusing to trading partners and providers. CAQH CORE adapted its CAQH CORE Master Companion Guide Template for Phases I, II, III, and IV CAQH CORE Operating Rules based on the CAQH/WEDI Best Practices Companion Guide Template, with input from multiple health plans, system vendors, provider representatives and healthcare/HIPAA industry experts. The CAQH CORE Master Companion Guide Template organizes information into several simple sections and provides for a common information flow and format, while at the same time giving health plans the flexibility to tailor the document to meet their particular needs. The CAQH CORE Master Companion Guide Template may be used for all HIPAA-mandated transaction sets.

20. Does the Phase IV CAQH CORE 452 Rule require HIPAA-covered entities to publish a Companion Guide if they do not currently do so?

No. Section 4.8 of the Phase IV CAQH CORE 452 Operating Rule specifies that should an entity publish a companion guide it must conform to the format/flow as defined in the CAQH CORE v5010 Master Companion Guide Template.

21. Does the Phase IV CAQH CORE 452 Rule require health plans to request approval from ASC X12 prior to publication of their CORE-conformant Companion Guide?

No. The Phase IV CAQH CORE Operating Rules do not require any entity to submit its Companion Guide to ASC X12 for review and approval prior to publication. 

Entities seeking CORE Certification are required to submit to the CAQH CORE-authorized Testing Vendor: 1) The Companion Guide’s table of contents and 2) A page showing the organization’s requirements for the presentation of segments, data elements and codes. The CAQH CORE-authorized Testing Vendor will evaluate these documents to determine if they are consistent with the format in the CAQH CORE v5010 Master Companion Guide Template.

NOTE: Phase IV CORE Certification will be available in Fall 2016. 

22. Can I combine multiple transaction sets in a single companion guide?

Yes. Entities, may, if they wish, combine their companion guides for separate transactions into a single document. The flow and format of the CAQH CORE v5010 Master Companion Guide Template would still need to be followed, but sections would need to be repeated, tables added for each additional transaction, etc., without altering the flow and format.

23. Does this rule apply if my organization does not conduct the ASC X12 v5010 278 transaction?

No. Per Section 3.2 of CAQH CORE 452 Rule, the rule applies when a HIPAA-covered health plan or its agent uses, conducts, or processes the ASC X12N v5010 278 transaction.

Additionally, per Section 3.3 of CAQH CORE 452 Rule, this rule does not require any entity to conduct, use, or process the ASC X12N v5010 278 transaction if it currently does not do so or is not required by Federal or state regulation to do so.

24. Why is there a variability in elapsed times for returning acknowledgements or responses between the four Phase IV CAQH CORE Infrastructure Rules?

The four Phase IV CAQH CORE Infrastructure Rules recognize that there are different business processes for the various transactions which have different capabilities. Therefore, through the rule development process, appropriate elapsed time requirements were determined individually for each Phase IV CAQH CORE Infrastructure Rule and its respective transaction focus.