Under HIPAA, are covered entities expected to expand their legacy systems to accommodate and store the maximum field lengths that could be sent in a transaction?
A majority of data elements on the HIPAA transactions have lengths in excess of the field lengths on our local record formats. An example would be a telephone number: the implementation guides and X12 standards allow for up to 80 alphanumeric bytes for a telephone number. In North America, a telephone number can be stored in 10 numeric bytes. Many legacy systems allow for a middle initial in an individual's name, but the NM1 segment allows for the transmission of an entire middle name. Some organizations may not have a business need for the middle name and can get by on just the middle initial.
No. Covered entities are not required by the rules to modify their legacy systems to accommodate and store the maximum field lengths. A health plan must be able to receive the maximum size at their front end and retain certain data required for exchanging coordination of benefits. A health plan may build the outbound X12N 837 for coordination of benefits using the data the health plan used to adjudicate the claim (data on claim history and other reference files). Data that a health plan receives, but doesn't use to process the claim, must be stored to be used later in building the outbound X12N 837 if they exchange coordination of benefits.