WEDI Acknowledgement Recommendations

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Acknowledgement Recommendations For ASC X12N Implementation Guides, Interchange Level through Conformance Checking Version 4.0 July 2008 Enclosure 2 Workgroup for Electronic Data Interchange 12020 Sunrise Valley Dr., Suite 100, Reston, VA. 20191 (t) 703-391-2716 / (f) 703-391-2759 Purpose: The purpose of this document is to describe the transactional accountability required to insure complete audit and control capability for the exchange of EDI.

Page 2 of 29 Disclaimer This document is Copyright 2008 by the Workgroup for Electronic Data Interchange (). It may be freely redistributed in its entirety provided that this copyright notice is not removed. It may not be sold for profit or used in commercial documents without the written permission of the copyright holder. This document is provided as is without any express or implied warranty. While all information in this document is believed to be correct at the time of writing, this document does not purport to provide legal advice. If you require legal advice, you should consult with an attorney. The information provided here is for reference use only and does not constitute the rendering of legal or financial advice by. The listing of an organization does not imply any sort of endorsement and takes no responsibility for the products, tools and Internet sites listed. The existence of a link or organizational reference in any of the following materials should not be assumed as an endorsement by. would like to acknowledge and thank X12 for assisting in this collaborative effort.

Page 3 of 29 Background This paper presents recommendations for standardizing acknowledgement reporting for HIPAA transactions that follow the ASC X12N Implementation Guides, from the interchange level through Implementation Guide and application conformance checking. In business today, there are hundreds of different systems that process data differently. Because of this, differing requirements are imposed on the electronic submissions from trading partners. There also are variances in the reporting mechanisms, which are intended to help submitters verify the compliance of their submissions with the electronic/business requirements of the receiving entity, and the acceptance/rejection of their submissions by the receiving entity. Response reports frequently are sent to submitters in proprietary formats or on paper and frequently lack the information needed by the submitter to resolve issues with rejected electronic submissions. With the advent of HIPAA and standard transaction sets, the ability exists to also standardize the acceptance or rejection reports. HIPAA makes this possible given that, at a minimum, healthcare trading partners will need to supply standard data content in HIPAA-mandated transaction sets. Standardizing the process for submitters and receivers will significantly reduce the costs associated with understanding and correcting errors. Once the healthcare industry standardizes the acknowledgement reports, correction and resubmission of returned/errored transaction sets will be expedited. This should result in quicker error correction and easier implementation of all transaction sets. Finally, standardized reporting will reduce the number of inquiries from trading partners regarding errors and reported information. Terminology The following definitions allow for a level and consistent interpretation of the terms. Accepted The interchange, functional group, transaction set or unit of work conforms to the syntax and business rules of X12, X12N (IGs) and of the receiver. Accepted with errors The interchange, functional group, transaction set or business unit contained errors, but will be accepted in its entirety and processed by the receiver. Authoritative source The authoritative source of the data is the entity submitting a unit of work, receiving a request or submitting a response to a request. Code - A code is a value from a predefined list of values that is maintained by ASC X12 or by other bodies that are recognized by ASC X12 and identified by reference in the code source appendix of the Implementation Guide.

Page 4 of 29 Companion Guide - Companion Guides are to be used in conjunction with HIPAA Implementation Guides and include trading partner specific business rules, edits and data requirements clarifications. Error Nonconformance with X12 or X12N syntax or Implementation Guide rules or nonconformance with the business rules of the receiver. (NOTE: Errors do not necessarily equal rejection.) Final disposition The final disposition is the last acknowledgment or paired response from the authoritative source of the data. No further communication is required. Functional group A collection of similar transaction sets enclosed by an ASC X12 functional group header and a functional group trailer.(gs/ge segment) Interchange A group or groups of ASC X12 transaction sets combined into one logical transmission (ISA/IEA segment). (Note: This may include more than one functional group of transaction sets.) Implementation Guide Set of standards developed by the ASC X12N sub-committee to specify format and data requirements to be used for the electronic transactions named within the HIPAA legislation. Implementation guides are also known as a Technical Report Type 3 (TR3). Receiver The entity that is the recipient of the communication. The term receiver may apply to providers, payers, clearinghouses or their business associates. Rejected The interchange, functional group, transaction set or business unit cannot be processed as sent. Stage Logical category of acknowledgment reporting. Standard Acknowledgement The standard acknowledgements are the X12 control transaction sets without industry specific implementation guidance. The 997, and 999 acknowledgement transactions have published implementation guides. The guides can be found at www.wpc-edi.com/registry. Submitter The entity that is the initiator of the communication. The term submitter may apply to providers, payers, clearinghouses or their business associates. Trading Partner Agreeement - an agreement related to the exchange of information in electronic transactions, whether the agreement is distinct or part of a larger agreement, between each party to the agreement. (For example, a trading partner agreement may specify among other things, the duties and responsibilities of each party to the agreement in conducting a standard transaction.) See

Page 5 of 29 Transaction set A group of logically related ASC X12 data business units contained within an ST/SE pair. Transition period A period of time which will allow submitters and receivers to progress to a new or subsequent version of a standard. During the transition period, dual use of the current method with the new or subsequent version of the standard may be needed. Unit of work A single business unit within a transaction set (e.g., one claim within a 837 transaction set, one remittance advice within a 835 transaction set, etcetera). (Note: A transaction set may include more than one unit of work.)

Page 6 of 29 Section 1: Submitters and Receivers In the industry today, the flow of transaction set acknowledgements typically is in one direction. For instance, while some provider systems and clearinghouses are built to pick up and act upon the acknowledgement reports from the payers, the reverse is not always true. Providers and clearinghouses cannot always issue an acknowledgement or error report to the payer because the payer infrastructure to handle that type of acknowledgement sometimes is not available. (can we make this more neutral) Table 1 Roles and Obligations, below, shows how industry constituents responsibilities change as submitters and receivers, based on the transaction sets. For simplicity s sake, the table shows only the initial submitter and the ultimate receiver. For a visual representation of the transaction set flow, including clearinghouses, see the business transaction flows on pages 18-22. It should be noted that one or more intermediaries or clearinghouses may be in between the initial submitter and ultimate receiver. Those intermediaries or clearinghouses may act as the submitter and receiver for the same transaction set. Table 1 Roles and Obligations, below, identifies the basic submitters and receivers by transaction set and provide guidelines for submitter and receiver responsibilities relative to the transaction set flow. It is assumed that all appropriate levels of acknowledgements will be used, depending on the stage of the rejection/error as described in Tables 2 and 3. For purposes of Table 1 Roles and Obligations, the initial submitter and ultimate receiver are identified as providers and payers with the understanding that intermediaries such as clearinghouses also may be in the workflow. Table 1 Roles and Obligations Transaction Set Eligibility Inquiry X12N 270 Eligibility Response X12N 271 Submitter Provider or Payer. If the submitter receives a response that the transaction set or unit of work was rejected, the submitter has the option of fixing and resending as needed. However, if resent, it should be formatted correctly. Payer. If the submitter receives a response that a batch transaction set or unit of work was rejected, it must correct Receiver Payer. The receiver must respond if unable to process the transaction set or unit of work. Provider or Payer. If the receiver receives an incorrect 271 transaction set, it has the option of requesting a

Page 7 of 29 Transaction Set Additional Information to Support a Health Care Claim or Encounter X12N275 Claim Status Request X12N 276 (paired with Claim Status Response, X12N 277) Claims Status Response X12N 277 Solicited Response to the 276 (paired transaction) Submitter and resend the transaction set. For real-time transactions, the submitter should take action as soon as possible to prevent a recurrence of the issue in future transactions. Provider. If the receiver is unable to process the X12 transaction set or embedded HL7 message, the submitter must correct and resend. Provider. The submitter has the option of fixing and resending a 276 transaction set or unit of work if the submitter receives a response that the transaction set or unit of work was rejected. If the submitter chooses to resend, the transaction set or unit of work should be formatted correctly. Payer. If the submitter receives a response that a batch transaction set or unit of work was rejected, it must correct and resend. For real-time transactions, the submitter should take action as soon as possible to prevent a recurrence of the issue in future transactions. Receiver corrected 271 transaction set. Payer. The receiver must respond if unable to process an X12 transaction set or embedded HL7 message. Payer. The receiver must respond if unable to process a claim status transaction set or unit of work request from a submitter. Provider. If the receiver receives an incorrect solicited 277 transaction set or unit of work, it has the option of requesting a corrected transaction set or unit of work.

Page 8 of 29 Transaction Set Request for Additional Information X12N 277 (paired with Additional Information to Support a Health Care Claim or Encounter X12N 275) Submitter Payer. If the submitter receives a response that a batch transaction set or unit of work was rejected, it must correct and resend if the submitter still needs the additional information. Receiver Provider. If the receiver receives an incorrect 277 request for additional information transaction set or unit of work, it must request a corrected 277 request for additional information. Request for Review X12N 278 Response to Request for Review X12N 278 Premium Payment X12N 820 Benefit Enrollment and Maintenance Provider. The submitter has the option of fixing and resending a 278 transaction set or unit of work if the submitter receives a response that the 278 transaction set or unit of work was rejected. Payer. If the submitter receives a response that a batch transaction set or unit of work was rejected, it must correct and resend the transaction. For real-time transactions, the submitter should take action as soon as possible to prevent a recurrence of the issue in future transactions. Sponsoring Entity/Employer. If the submitter receives a response that the transaction set or unit of work was rejected the submitter should resubmit. Sponsoring Entity/Employer. If the submitter receives a response that the transaction set or unit of Payer. The receiver must respond to the provider if unable to process a 278 authorization or referral transaction set or unit of work request. Provider. If the receiver receives an incorrect 278 transaction set or unit of work, it has the option of requesting a corrected 278 transaction set or unit of work. Payer. The receiver must respond if unable to process a transaction set or unit of work. Payer. The receiver must respond if unable to process a transaction

Page 9 of 29 Transaction Set X12 N 834 Claim Payment/Re mittance Advice X12N 835 Health Care Claim (all versions) X12N 837 Submitter work was rejected the submitter should resubmit. Payer. If the submitter receives a response that a batch transaction set or unit of work was rejected, it must correct and resend Provider or Payer. If the submitter receives a response that a batch transaction set or unit of work was rejected, it must correct and resend if the submitter still needs the claim to be processed. Receiver set or unit of work. Provider. The receiver has the option of requesting that the payer correct the transaction set or unit of work if unacceptable. Payer. The receiver must respond if unable to process the transaction set or unit of work. Note: if a submitter receives a response that a a batch transaction set or unit of work was rejected, and after reviewing the rejection response believes the rejection was inappropriate, they should contect the rejection sender to resolve the issue. Recommendation 1.1 Receiving partners shall return appropriate acknowledgements as defined below in Tables 2 and 3. Responses should meet the timeliness requirements specified in the service level or trading partner agreement. Recommendation 1.2 If the receiving partner sends a rejection message in an acknowledgement, the submitter may act on the rejection by correcting the error and resending a corrected transaction set. (Note: In some instances, a clearinghouse or intermediary may not be able to immediately correct the data content in error. In those instances, the acknowledgement or response should be returned to the initial submitter.) Recommendation 1.3 The submitter shall receive acknowledgements as shown in Tables 2 and 3 and shall not reject an acknowledgement as a non-supported transaction.

Page 10 of 29 Section 2: Acknowledgment and Rejection Reporting Mechanisms believes that acknowledgment of receipt and reporting of rejections between trading partners currently is inconsistent and incomplete. Although no acknowledgement and reporting mechanisms are mandated by the HIPAA Transactions and Code Sets Final Rule, it is important that an accurate audit trail be maintained to provide relevant feedback between trading partners. To solidify the audit process and add value to the transaction set processing cycle, it is critical to include complete, accurate and consistent reporting mechanisms between trading partners. Standard acknowledgements will significantly improve accountability, quick resolution of issues, resubmission of rejected transaction sets and/or units of work, and correction and improvement of submitter systems based on errors accepted but advised. This document uses the term stage to indicate a logical category of acknowledgement reporting. The stages may be thought of as though they take place in sequence. However, computer systems usually are programmed to perform error checking for the several stages in parallel, and this document is not intended to imply that the processes should be serial. Rather, the stages are meant to assist in understanding categories and to separate functions that should be the same across the industry from functions that are specific to individual entities. Following are the multiple stages of acknowledgement reporting covered in this paper: (see image 1) 1. Transaction set interchange validation 2. Format (X12) syntax checking (described in the columns for functional group and transaction set syntax in Tables 2 and 3. 3. HIPAA implementation guide conformance checking. 4. Entity-specific pre-application validation, such as for companion guide requirements. (for 277 claims acknowledgment only).

Page 11 of 29 Image 1. Note: the TA3 and 824 are not included within the scope of this document or recommendations. Recommendation 2.1 Acknowledgment and reporting of errors for the first three stages above (interchange validation, syntax checking and Implementation Guide conformance checking) shall be implemented by all participants as outlined in Tables 2 and 3. In contrast, the use of pre-application validation and application processing are specific to each participant. However, if implemented, they must be reported with the acknowledgement reporting standards shown in Tables 2 and 3. Recommendation 2.2 Code values as defined in each Implementation Guide as applicable to each specific acknowledgement and/or response shall be adopted.

Page 12 of 29 Section 3: Recommended Stages of Acknowledgement Reporting or Response (NOTE: To see the enveloping and looping structures within X12 transaction sets, see Appendix A, attached.) Interchange Stage An interchange stage is the stage that validates a transaction at the X12 interchange level. This validation reviews the ISA and IEA segments and their consistency with the data they contain. Most X12 interchange errors will cause the receiver to reject the entire interchange with no further processing, but the receiver could accept or correct certain errors if they do not affect translation of the transaction set units of work. X12 interchange errors will be reported in the TA1 segment. Functional Group Stage The X12 functional group validation is enforced for functional group level problems. This validation reviews the GS and GE segments and their consistency with the data they contain. Most X12 functional group errors will cause the receiver to reject the entire functional group with no further processing, but the receiver may accept or correct certain functional group errors if they do not affect the translation of the transaction set units of work. The receiver will report all detected errors, whether resulting in rejection, acceptance or acceptance-with-error, with the 999 transaction set. Transaction Set X12 Syntax Stage An X12 transaction set may contain one or more units of work. A transaction set syntax validation analyzes the transaction set and reports X12 syntax problems. This validation reviews the ST and SE segments, as well as the transaction set segments and elements and their consistency with the data they contain. An error affecting one or several units of work within a transaction set must not cause adverse action against other valid units of work within the transaction set. This may require an accept-with-errors of the transaction set at this stage so as to accept transaction set at this stage and either accept or reject the individual units of work at a subsequent stage. This is possible only if the syntax errors are not of a critical nature and do not force the rejection of the entire transaction set. An error in one transaction set must not affect the processing of other transaction sets contained in the functional group or interchange envelopes. The receiver of the transaction set will report all detected errors (whether resulting in rejection, acceptance or acceptance-with-error) with the 999.

Page 13 of 29 Implementation Guide Conformance Stage An Implementation Guide (IG) conformance validation analyzes the transaction set for IG conformance problems. This validation varies depending on the implementation guide being used, as the code sets, looping structures and other implementation guide specific conformance requirements vary somewhat. At this stage, the validation should be limited to what is described in the IGs and not include the application validation described below. For example, Companion Guide requirements should not be included at the IG conformance validation stage. All errors must be reported to the submitter, including when the transaction set is accepted-witherrors. IG errors apply to data contained within the industry-defined looping structure (for example, to a single claim or all the claims for a specific billing provider). Subsequent units of work within the same transaction set must be accepted provided no problems were found within their segments or loops. The scope of error action is limited to the unit of work in violation of the IG restriction and cannot exceed a transaction set. See Tables 2 and 3 below for the acknowledgement reporting mechanisms for each transaction set. Pre-application Validation Stage Pre-application validation may be performed in the front-end system, but is applicationspecific and not related to the X12 or IG conformance of a transaction set. Typically, Companion Guide validation will be implemented at the application validation stage. Although error messages generated from application validation are specific to a trading partner, business situation or application, they are generated before the transaction set is processed through an application. They typically are created to detect common and/or obvious errors so as to expedite advising the submitter and eliminate delays caused by flawed transaction sets or units of work moving forward through an application or adjudication system. They may report acceptance, acceptance-witherror, correction or rejection. As stated above, it is important to differentiate application messages from EDI messages for ease and consistency in implementation across trading partners. An example of an application validation could be checking the structure of a subscriber ID. The 277 Claim Acknowledgement transaction set is the appropriate acknowledgement transaction set for the X12N 837 transaction set. See Tables 2 and 3 below for the application reporting mechanisms for each transaction set at each stage. Recommendation 3.1 The stages described above shall be applied throughout the health care industry and on all X12N HIPAA transaction sets. The stages indicate the appropriate acknowledgment and/or error report to be returned for each transaction set as specified in Tables 2 and 3.

Page 14 of 29 Recommendation 3.2 The industry shall begin voluntary adoption of the 999 transaction set for the functional group, X12 syntax, and IG conformance stages transitioning from the 997 transaction set to the 999 transaction set in accordance with the timeline shown in Appendix B, attached. Recommendation 3.3 Acknowledgements shall be implemented as recommended in the Legend for Tables 2 and 3. Legend for Tables 2 and 3 Transaction Set Description Recommendation TA1 Interchange Acknowledgement. This segment acknowledges the receipt of an X12 interchange header (ISA) and trailer (IEA) from a previous interchange. If the header/trailer pair is received correctly, the TA1 reflects a valid interchange, regardless of the validity of the data contents within the header/trailer envelope. Use of the TA1 is subject to trading partner agreement and is not required. For real-time transaction sets when the communication is held open, if the communication is successful, a TA1 is not needed. 270 Eligibility Inquiry. The 270 was adopted by HIPAA as the standard transaction set to carry one or more eligibility inquiry units of work. 271 Eligibility Response. The 271 was adopted by HIPAA as the standard transaction set to carry one or more eligibility response units of work, which are the business responses to eligibility inquiry units of work. 275 Claim Attachment. Final Rule Pending 276 Claims Status Inquiry. The 276 was adopted by HIPAA as the standard transaction set to carry one or more claims status inquiry units of work. The TA1 report should be used at the interchange stage. The TA1 acknowledges receipt and reports that the interchange has been accepted, accepted-with-errors or rejected. If the entire interchange is rejected, the only acknowledgement required is the TA1.

Page 15 of 29 Transaction Set Description Recommendation 277 Claim Status Response (paired with the 276) 277 Health Care Claim Acknowledge ment (277CA) 277 Request for Additional Information Claims Status Response. The 277 was adopted by HIPAA as the standard transaction set to carry one or more claims status response units of work, which are the business responses to the 276 claims status inquiry units of work. The Health Care Claim Acknowledgment 277 was sometimes previously referred to as the unsolicited 277. When used as an acknowledgement, the 277 should be used to communicate the total number of claims accepted, pended or rejected, and the reasons for pending or rejecting the claims. The previous 'Unsolicited 277 had the Acknowledgement function AND also the Pending claim list function. Those functions are now in 2 different guides. The 277CA only has the ability to indicated Accepted or Rejected in the adjudication system. Request for Additional Information. The 277 will serve as the claim attachment request for additional information.(final Rule Pending) 278 Referral Certification and Authorization. The 278 was adopted by HIPAA as the standard transaction set to carry one or more requests for authorization for health care, requests for referral or the business responses to these requests. 820 Premium Payment. The 820 was adopted by HIPAA as the standard transaction set for the premium payment The 277 Health Care Claim Acknowledgment should be created by the receiver of the 837 claim transaction set to acknowledge to the submitter each unit of work (claim or encounter), regardless of whether the unit of work was accepted into the adjudication system or rejected. Having an automated acknowledgement would allow clearinghouses and/or providers to retain the audit trail of information without handling or storing paper and allow for automated tracking of claims to focus on those rejected or that contain errors.

Page 16 of 29 Transaction Set Description Recommendation transaction. 834 Health Plan Enrollment and Disenrollment. The 834 was adopted by HIPAA as the standard transaction set to carry one or more enrollment or disenrollment units of work. 835 Remittance Advice. The 835 was adopted by HIPAA as the standard transaction set to carry one or more electronic remittance advices describing denial, payment or partial payment of a health care or NCPDP claim. The 835 also was adopted as the standard transaction set to carry one or more payment orders. 837 Claim. The 837 was adopted by HIPAA in three different Implementation Guides as the standard transaction set to carry one or more health care claims or encounters. 997 Functional Acknowledgment. The 997 is a transaction set that carries acknowledgments to indicate the results of the syntactical analysis of the X12 transaction sets and functional groups contained within an X12 interchange (found between the ISA and IEA). 999 Implementation Acknowledgment. The 999 is a transaction set that indicates the results of the conformance analysis of the X12 transaction sets and functional groups contained within an X12 interchange against the requirements of both X12 syntax and Implementation Guide constraints. This 999 transaction set is available only in X12 version 5010 and later, but still may be used for acknowledging prior versions of the standard. X12 has approved the 999, so the 997 should be used only for acknowledgement or X12 syntax error reporting during the transition period noted in the timeline in Appendix B. The 999 implementation guide emphasizes use of the accept-with-errors functionality so it is possible to accept individual units of work at a later stage without forcing the rejection of the entire transaction set with a 999 when the errors affect only one unit of work within the transaction set. The scope of error action is

Page 17 of 29 Transaction Set Description Recommendation limited to the unit of work in violation of the IG restriction and cannot exceed a transaction set.

Page 18 of 29 Tables 2 and 3 reflect the business process models and final disposition of the exchange. The determination of final disposition is related to the authoritative source of the data. Therefore, the authoritative source of the data will always communicate the final disposition. Any further communication after final disposition will need to be pursued through other means of communication, whether that be sending an additional electronic communication or fax, or via telephone. This approach was used when creating Tables 2 and 3. Table 2 Real-time Acknowledgements Transaction Set Interchange Functional Group/ Transaction Set Syntax/ IG Conformance Pre-application Validation (companion documents) Application Results 270 TA1 (1) 999 (2) 271 (4) 271 271 TA1 (1) 999 (2) N/A N/A 276 TA1 (1) 999 (2) 277 (4) 277 277 Response to 276 TA1 (1) 999 (2) N/A N/A 278 TA1 (1) 999 (2) 278 (4) 278 835 (3) TBD TBD TBD TBD 837 (3) TBD TBD TBD TBD (1) Do not use with real-time transactions (that is, when the communication is held open) to report valid interchanges. Use only with real-time transaction when the interchange envelope (ISA) contains errors. (2) Do not use with real-time transactions to report valid syntax within a GS/GE functional group or ST/SE transaction set. Use only with real-time transactions when the functional group or transaction set contains errors. (3) Real Time Adjudication business process is not yet completed for the 835 and 837. Acknowledgement process will be determined later. (4) The application results transaction set also may be used in the pre-application stage.

Page 19 of 29 Table 3 Batch Acknowledgements Note: Items in grey are not included in the scope of this document. X12 IG Business Transaction Set Interchange Functional Group/ Transaction Set Syntax/ IG Conformance Pre-application Validation (companion documents) Application Results 270 TA1 999 271* 271 271 TA1 999 824 824 275 TA1 999 824 835 276 TA1 999 277* 277 277 Response to 276 277 Request for Additional Info TA1 999 824 824 TA1 999 824 275 277CA TA1 999 824 N/A 278 TA1 999 278* 278 820 TA1 999 824 N/A 834 TA1 999 824 N/A 835 TA1 999 824 824 837 TA1 999 277CA x214 835 Note: TA1 shall be sent by the receiving organization at the request of the transaction originator, otherwise it may be sent at the option of the receiving organization. *The application results transaction set also may be used in the pre-application stage. Other acknowledgements shall be sent if transaction rejected, or upon request of the originator of the transaction per trading partner agreement, except 277CA which shall always be sent.

Page 20 of 29 Entities moving from 997 to 999 should use 999 for same functions as 997 is being used, then in next steps expand to IG syntax edits only and exclude external code sets, and then determine the business issues to be included in the 999. SNIP, working in cooperation with X12 will be asked to consider implementation issues including recommendations for when and where additional uses supported by the 999, such as implementation guide conformance and editing for values in external code sets should be implemented.

Page 21 of 29 Business Transaction Set Flows The following business transaction set flows illustrates the recommendations made above. Clearinghouses (possibly multiple clearinghouses) may be employed by either the providers or payers to send and receive the transaction sets being exchanged. However, the most complex situation in this illustration assumes that only one provider clearinghouse and one payer clearinghouse are involved. Five distinct examples are displayed below, but by no means should these examples lead the reader to believe that these are the only situations occurring. A payer frequently will receive transaction sets from individual providers, as well as from many clearinghouses. The acknowledgement transaction sets should remain the same, regardless of whether the receiver is responding to an individual or a clearinghouse. For purposes of this paper, the examples are simplified for reasons of clarity. All of the 277 transaction sets noted in the examples below refer to the 277 claim acknowledgement transaction set: 1. Example 1 illustrates a situation in which the provider is sending directly to a payer and no clearinghouse is involved. 2. Example 2 illustrates a situation in which the provider has employed the services of a clearinghouse and the clearinghouse sends directly to the payer. 3. Example 3 illustrates a situation in which the payer has employed the services of a clearinghouse and the provider sends directly to the payer s clearinghouse. 4. Example 4 illustrates a situation in which the provider and payer both have employed the services of different clearinghouses.

Page 22 of 29 Example 1 1 (837) Provider 2 (TA1) 3 (999) 4 (277) 5 (835) 6 (TA1+999) Payer In this example, the 837 transaction set is sent directly from the provider to the payer: 1. The provider sends the payer an 837 transaction set. 2. The payer checks the X12 interchange during the communication session. The resulting acknowledgement is the TA1 transaction set. 3. The payer checks the functional group, Transaction Set X12 syntax and X12N Implementation Guide conformance. The resulting acknowledgement is the 999 transaction set. This acknowledgement may be given during the communication session; however, in some cases, the acknowledgement will be ready for retrieval at a later time, such as during the next communication session. 4. The payer validates the transaction set against the payer s own companion guide and generates a 277 Claim Acknowledgement (277CA) transaction set to identify accepted and rejected units of work before processing the transaction set through the application stage. This acknowledgement may be produced some time after the 837 has been received. 5. The payer creates the 835 transaction set. 6. The provider validates the 835 transaction set and creates the TA1 and 999 transaction sets. Nonconformities, such as transaction set syntax errors or out-ofbalance errors, must be corrected by the payer and the 835 transaction set then must be resent.

Page 23 of 29 Example 2 2 1 3 4 Provider 5 Provider Clearinghouse Payer 9 8 6 7 In this example, the batch 837 transaction is sent from provider to payer via the provider s clearinghouse: 1. The provider sends an 837 transaction set to its clearinghouse. 2. The clearinghouse responds with TA1, 999 and 277 Claim Acknowledgement (277CA) transaction sets. (Note: The 999 and 277 may or may not occur within the same communication session. The 999 and 277 may be made available at a later time.) 3. The clearinghouse sends an 837 transaction set to the payer. 4. The payer responds with TA1, 999 and 277 Claim Acknowledgement (277CA) transaction sets. (Note: The 999 and 277 may or may not occur within the same communication session. The 999 and 277 may be made available at a later time.) 5. The clearinghouse passes the payer s 277 Claim Acknowledgement (277CA) transaction set back to the provider. (Note: Rejects identified in the TA1, 999 received by the clearinghouse from the payer would be rejects that the clearinghouse would need to address. The 277 Claim Acknowledgement (277CA) rejections would be addressed by the provider. The 999 and 277 may or may not occur within the same communication session. The 999 and 277 may be made available at a later time.) 6. The payer sends the 835 remittance transaction set to the clearinghouse. 7. The clearinghouse responds with TA1 and 999 transaction sets. (Note: Rejections at this stage need to be addressed by the payer.) 8. The clearinghouse send the 835 remittance transaction set to the provider..

Page 24 of 29 9. The provider responds with TA1 and 999 transaction sets. (Note: Rejections at this stage need to be addressed by the clearinghouse.) Example 3 2 1 3 4 Provider Payer Clearinghouse Payer 5 6 In this example, the 837 transaction is sent from provider to payer via the payer s clearinghouse: 1. The provider sends an 837 transaction set to the payer s clearinghouse. 2. The clearinghouse responds with TA1, 999 and 277 Claim Acknowledgement (277CA transaction sets. (Note: The 999 and 277 may or may not occur within the same communication session. The 999 and 277 may be made available at a later time.) 3. The clearinghouse passes the 837 transaction set to the payer. 4. The payer sends the 277 Claim Acknowledgement (277CA and 835 remittance transaction sets to the clearinghouse. 5. The clearinghouse sends the payer s 277 Claim Acknowledgement (277CA and 835 remittance transaction sets to the provider. 6. The provider responds with TA1 and 999 transaction sets. (Note: Rejections from the TA1 or 999 transaction sets need to be addressed by the clearinghouse.)

Page 25 of 29 Example 4 Payer Clearing house 5 9 6 1 4 8 Payer Provider 2 3 7 10 11 Provider Clearing house In this example, the 837 transaction is sent from provider to payer via the providers s clearinghouse and then sent to the payer s clearinghouse by the provider s clearinghouse: 1. The provider sends the 837 transaction set to the provider s clearinghouse. 2. The provider s clearinghouse responds to the provider with TA1, 999 and 277 Claim Acknowledgement (277CA) transaction sets. (Note: The 999 and 277 may or may not occur within the same communication session. The 999 and 277 may be made available at a later time.) 3. The provider s clearinghouse sends the 837 transaction set to the payer s clearinghouse. 4. The payer s clearinghouse responds to the provider s clearinghouse with TA1 and 999 transaction sets, and possibly the 277 Claim Acknowledgement (277CA) transaction set if that functionality exists at the payer s clearinghouse. (Note: The 999 transaction set may not be returned within the same communication session, but may be available at a later time.) 5. The payer s clearinghouse passes the 837 transaction set to the payer. 6. The payer sends to its clearinghouse the 277 Claim Acknowledgement (277CA) (if not created by the payer s clearinghouse) and 835 remittance transaction sets. 7. The payer s clearinghouse sends the 277 Claim Acknowledgement (277CA) and 835 remittance transaction sets to the provider s clearinghouse.

Page 26 of 29 8. The provider s clearinghouse responds with TA1and 999 transaction sets. (Note: Some rejections at this stage need to be addressed by the payer s clearinghouse; others may need to be returned to the payer.) 9. The payer s clearinghouse returns rejections to the payer. Rejections such as outof-balance transaction sets must be corrected by the payer and resent. 10. The provider s clearinghouse sends the 835 and 277 Claim Acknowledgement (277CA) transaction sets to the provider. The 277 Claim Acknowledgement (277CA) transaction set would be errors the provider would need to address. 11. The provider responds with TA1 and 999 transaction sets. (Note: Rejections at this stage need to be addressed by the provider s clearinghouse.)

Page 27 of 29 Appendix A Reference Diagram: Enveloping and Looping Structures within X12 Transaction Sets Washington Publishing Company 2005. Reprinted with permission.

Page 28 of 29 Appendix B Recommended Acknowledgement Implementation Time Line (as of April 2008) Note: The tasks in this recommendation will be referred to SNIP for development of a more detailed implementation task list Proposed Task Implementation Start Date Proposed Task Completion Date Proposed Implementation Task 8/1/2008 Ongoing Education sessions on acknowledgement transactions 10/1/2008 4/1/2009 Pilot tests for the TA1 transaction set and 999 transaction sets 4/1/2009 10/1/2009 ROI Evaluation of Pilot tests 9/1/2008 9/1/2009 Pilot tests of 277 CA, and evaluation of ROI for moving from current acknowledgement implementations to 277 CA 10/1/2009 9/1/2010 Transition to TA1, 999, and 277CA 9/1/2010 Full implementation of the TA1, 999, and 277CA on all relevant transaction sets.

Page 29 of 29 Appendix C Recommended Next Steps Board to ask SNIP in collaboration with X12 to Recommend an implementation approach and associated time frames for each standard based on each stakeholder group [i.e. Health Plan, Provider, Clearinghouse, Vendor, etc.] and recommend migration paths for trading partners. Identify implementation issues and work with appropriate stakeholders to resolve them and/or to facilitate resolution of ambiguities within standards and rules. Serve as a resource, in coordination with the Acknowledgement Task Group to help facilitate resolution of business issues arising from implementation. Coordinate recommendations, proposals and strategies in collaboration with the Acknowledgements Task Group and Policy Advisory Groups (PAGs) Acknowledgements Task Group to work with SNIP in collaboration with X12 to develop pre application validation and application results validation recommendations, and facilitate resolution of business issues arising from implementation,