Is the payer allowed to wait until the compliance deadline to conform to requirements that prohibit changing of code descriptions?
Yes, they can wait. But the proactive payer is actively working to achieve full HIPAA compliance as soon as possible to guarantee they are not subject to HIPAA transaction and coding penalties on October 16, 2003. Back to top Must providers and payers break out coding for all of the dispensed drugs, including even diluents, flushing solutions, D5W, etc. in claims? Or, could they agree to include some drugs as part of the per diem when the HCPCS per diem “S” codes are used? Under HIPAA rule, providers, payers and clearinghouses may not change the meanings of HCPCS or CPT descriptions within an electronic claim. See the FAQ on the relevant regulations. Therefore, because most of the HCPCS per diem “S” codes for home infusion therapy specify “drugs and nursing visits coded separately”, drugs cannot be included in the per diem. To do otherwise would be an enforceable violation of HIPAA law. Thus, drugs are coded and paid for separately. Break out from the per diem all non-compounded drugs