1. Comment: One commenter suggested that the X12N (the ASC X12 subcommittee chartered to develop electronic standards specific to the insurance industry) implementation specifications under HIPAA must be flexible to permit businesses to customize their EDI process. It was stated the implementation specifications do not allow flexibility between trading partners.
Response: We disagree. Allowing flexibility would result in non-standard implementation of the transactions. The X12N implementation specifications under HIPAA, adopted in this final rule, are all version 4010. If businesses customize implementations of 4010, the health care industry would have hundreds of different implementations of the same transaction.
2. Comment: One commenter recommended we include the following language: “In addition, a set of NCPDP standards contains all of the approved standards and implementation specifications. For an additional fee, the data dictionaries are available.”
Response: We are aware that data dictionaries are available and that there is a charge separate from the membership fee for them. We do not believe this needs to be included in the final rule, since this information is available through the NCPDP web site.