AUC UPDATE
April 8, 2016
In this issue:

National CAQH Study
Highlights Progress,
Additional Opportunities in
Electronic Health Care
Transactions ---p.1

Clarification/Reminder – 835
ERA and payment must have
appropriate trace numbers
for reassociation – p.3

Coding corner – p.4

TAG updates – p.5

National News - p.7

AUC April- May 2016 Meeting
Calendar – p.8
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Volume 4, Number 3
National CAQH study highlights progress,
additional opportunities in electronic
health care transactions
For the past three years, the national CAQH has published an
index of electronic “administrative transaction adoption and
savings.” The 2015 CAQH Index, reporting data for 2014, has
recently become available. Data for the Index was obtained from
surveys of health care providers and health plans. The health
plans taking part in the study had a combined enrollment of over
118 million covered lives, or about 45% of the US commerciallyinsured population.
Like the proverbial glass half-full, the latest, most recently
released CAQH Index reported on progress in the adoption of
electronic health care administrative transactions, as well as work
still needed to bring about greater adoption of e-transactions and
corresponding administrative simplification savings. According to
the 2015 Index:

Over the past three iterations of the survey (2012-2014),
there has been a modest, but steady growth in the adoption
of electronic health care business transactions;

Despite the modest growth in electronic transactions noted
above, rates of adoption for electronic health care
administrative transactions varied considerably depending on
the transaction. Electronic claims had the highest adoption
rate (94%), while electronic prior authorization had an
adoption rate of only 10%.
Below is a table comparing the most recent CAQH Index levels of
electronic transactions and the levels reported in a 2015 survey
of ambulatory clinics in Minnesota (see February 2016 edition of
this newsletter for information regarding the ambulatory clinic
survey).
AUC Update
Transaction
Claims
Insurance
eligibility
Remittance
advices

Volume 4, Number 3
Percent
Percent
electronic, electronic,
Minnesota national
CAQH
Index
94%
94%
77%
71%
77%
50%
Page 2

Industry and government collaboration to
provide ongoing outreach and education
about the value of and need for adoption of
electronic transactions;

Consider changing and broadening the
current segmented federal regulation and
limited federal enforcement of etransactions requirements;

Coordinate federal administrative
simplification and health IT efforts while
taking into account market resources
required for clinical and administrative
implementation;

Consider financial incentives and contractual
requirements to reduce adoption barriers
for health plans and health care providers;

Monitor the transition to fully electronic
transactions to better evaluate initiatives
driving the adoption of e-transactions,
determine possible cost savings, and to
identify opportunities for further
improvements.
The Index also cited significant savings
potential from using electronic vs. manual
business transactions.
o On average, manual transactions cost
providers and health plans
approximately $2 more per transaction
than comparable electronic transactions.
o The transaction with the biggest cost
difference was prior authorization, at an
average cost each of $10.83 for manual,
and $2.51 for electronic.
o For health plans, the average cost of
manual versions of six common
transactions* was $2.30 per transaction,
vs. $.0.04 per electronic transaction – a
nearly 60 fold difference.
*(claim submission, status inquiry,
payment, eligibility and benefit
verification, prior authorization, and
remittance advice)
Given the findings above, the Index issued an
“industry call to action” with a number of
recommendations to accelerate the transition to
electronic transactions, including:

April 8, 2016
Adoption and sharing of best practices that
promote the adoption and use of etransactions;
For more information, see the 2015 CAQH
Index.® Electronic Administrative Transaction
Adoption and Savings Calendar Year 2014
http://www.caqh.org/sites/default/files/explora
tions/index/report/2015-caqh-index-report.pdf.
AUC Update
Volume 4, Number 3
April 8, 2016
Page 3
Clarification/Reminder – 835 ERA
and payment must have
appropriate trace numbers for
reassociation
The Minnesota Department of Health (MDH)
provides technical assistance for the
implementation of the state’s requirements for
the standard, electronic exchange of health care
administrative transactions (Minnesota Statutes,
section 62J.536), and provides the following
update below.
Summary
MDH was recently made aware of a situation in
which a health care provider received electronic
funds transfer (EFT) payments from a payer that
did not include the Reassociation Key Segment
TRN trace number needed for reassociating the
payment with the 835 remittance advice. The
purpose of this article is to remind providers and
payers that are subject to MS §62J.536 that
payers must include the appropriate number on
the payment to permit reassociation of the
payment with the information provided in the
v5010 X12 835 remittance advice.
Background
Minnesota Statutes, section 62J.536 and related
rules do not require payment via EFT. However,
regardless of whether payment is made by
check or via EFT, the law requires that payers
must transmit to providers the health care
payment and remittance advice transaction
described under Code of Federal Regulations,
title 45, part 162, subpart P. Two provisions of
subpart P -- 45 CFR §162.1602 and §162.1603 –
list the standards that have been adopted for
the transaction, which include the Phase III
CORE 370 EFT & ERA Reassociation (CCD+/835)
Rule, version 3.0.0.
The CORE 370 Rule requires that certain
minimum data elements be exchanged in the
EFT and remittance components of the
transaction, including the X12 835 TRN –
Reassociation Trace Number segment and
particularly the TRN02 Reference Identification
data element. According to instructions in the
applicable X12 835 standard adopted under the
CFR provisions above, “If payment is made by
check, [the TRN02] must be the check
number. If the payment is made by EFT, [the
TRN02] must be the EFT reference number.”
A copy of the CORE 370 Rule with additional
detail
(http://www.caqh.org/sites/default/files/core/p
hase-iii/policyrules/EFTERA_Reassociation_Rule.pdf) provides
several useful instructions and reminders. For
example, it notes that there are two different
types of trace numbers: the “ACH Trace
Number” and the “ASC X12 EFT Reassociation
Trace Number” (e.g., the TRN segment, including
especially the TRN02 data element). The
numbers are often confused with each other but
they are not the same and they are not
interchangeable. Of the two forms of the trace
number, the ASC X12 EFT Reassociation Trace
Number “is the only trace number that is used to
match the EFT to the corresponding ERA.”
In summary, based on the above, if payment is
made by check, the TRN02 data element on the
corresponding 835 remittance advice must be
AUC Update
Volume 4, Number 3
the check number. If payment is made by EFT,
the TRN02 data element on the corresponding
835 RA must be the EFT reference
number. Additional guidance for meeting these
requirements can be found in the CORE 370
Rule.
MDH encourages sharing the above information
as needed to help resolve any issues, questions,
or concerns. MDH is also available to discuss
the above or other administrative simplification
questions or issues at any time.
Note: Anyone may also submit the complaint
form at
http://www.health.state.mn.us/asa/asadocs/co
mplaintform.pdf to request investigations of
possible noncompliance with state’s
requirements for standard, electronic health
care administrative transactions.
In addition, anyone may submit complaints of
possible noncompliance related to
administrative simplification (transactions and
codes sets, unique identifiers) provisions of the
federal Health Insurance Portability and
Accountability Act of 1996 (HIPAA), to the
Centers for Medicare & Medicaid Services (CMS)
Office of E-Health Standards & Services
(OESS). Any individual who wishes to submit a
complaint may do so through the Administrative
Simplification Enforcement Tool (ASET) at
https://htct.hhs.gov/aset/HIPAA%20Transaction
s%20and%20Code%20Sets.jsp?agree=yes.
When filing a complaint, the complainant has
the option for remaining anonymous.
Note: HIPAA Privacy and Security complaints
must be directed to the Office for Civil Rights
(OCR at www.hhs.gov/ocr/hipaa), which has
responsibility for enforcing HIPAA Privacy and
Security violations.
April 8, 2016
Page 4
Coding Corner
The Coding Corner is a collection of updates , tips,
and pointers intended to help address common
medical coding issues and to pass along coding news
and updates suggested by the AUC’s Medical Code
TAG and other sources.
MUCG change in language, but not
intent, for how to report time-based
therapy services (OT/PT/SLP)
The 837 Professional (837P) and 837
Institutional (837I) Minnesota Uniform
Companion Guides (MUCGs) have long required
the use of the HCPCS/CPT rounding guidelines
for the timed-based therapy services, in which a
unit of time is attained when the midpoint is
passed. The language that was used to
communicate this in the 837P and 837I MUCGs
however was “Do not follow Medicare rounding
rules,” which has created some confusion.
In order to be more clear and direct, this
language has been removed from the guide and
replaced with instructions to follow HCPCS/CPT
rounding guidelines for reporting occupational
therapy/physical therapy/speech-languagepathology (OT/PT/SLP) services.
Below is an example (see figure 1) of accurate
coding and unit submission for “timed” HCPCS
therapy codes for non-Medicare encounters.
When only one service is provided in a day,
providers should not bill for services performed
AUC Update
Volume 4, Number 3
for less than 8 minutes. When more than one
service represented by 15 minute timed codes is
performed in a single day, the total number of
minutes of service determines the number of
timed units billed. This is an accepted “rounding
rule” practice not only by Medicare but for
other payers as well.
Figure 1
Services Performed
7 minutes of neuromuscular
reeducation, code 97112
8 minutes of therapeutic
exercise, code 97110
Units to Report
April 8, 2016
Committee reviewed items that it later
approved via email votes, including: proposed
changes to be adopted into rule for the
Acknowledgment Companion Guides; and data
content and format recommendations for
Accountable Care Organization (ACO) attributed
member files.
The Committee also reviewed the following
information and presentations regarding:

A summary of the National Committee on
Vital and Health Statistics (NCVHS) 2015
hearing on the “Status of Adopted
Standards, Code Sets, Identifiers, and
Operating Rules.” NCVHS found an “entire
ecosystem” is moving “towards
administrative simplification” with “evidence
of savings through the adoption and
implementation of standards for the HIPAA
named transactions.” However, it also
noted that “…achieving the potential savings
have been limited by a number of factors”
and that more work was needed to
“continuously improve the adopted
transaction standards and operating rules,
increase their level of implementation, and
improve the consistency in the way they are
implemented and used.” The summary
made several recommendations to address
the limiting factors above and to improve
the adoption and use of electronic health
care business transactions. (More
information is available in the February 29,
2016 NCVHS letter to Centers for Medicare
& Medicaid Services (CMS) Secretary
Burwell, http://www.ncvhs.hhs.gov/wpcontent/uploads/2013/12/2016-Ltr-toBurwell-Findings-of-RC-Adm-Simp-June2015-Hearing-Word.pdf)

The results of a 2015 survey of Minnesota
ambulatory clinics regarding their adoption
and use of four key electronic health care
administrative transactions: claims,
97110 = 1 unit
Because code 97112 was not rendered for at
least eight minutes, it is not reportable. The rule
for reporting units for timed codes is that at
least half of the time noted in code description
must be performed before it can be billed.
TAG Updates
Information ab out AUC committees and Technical
Advisory Groups (TAGs) and their activities, including
meeting minutes, can be accessed from the AUC TAG
page
(http://www.health.state.mn.us/auc/activity.htm).
Meeting agendas and other materials are posted on
the AUC website in advance of meetings. TAG
meeting schedules and information are also
available on the AUC calendar page
(http://www.health.state.mn.us/auc/calendar.htm).
With the exception of the Medical Code TAG, TAG
meetings are generally conducted via teleconference
rather than in-person. All AUC meetings are open,
public meetings.
OPERATIONS COMMITTEE
The AUC Operations Committee met on March
8, 2016 at the TIES Event Center in Falcon
Heights (St. Paul), Minnesota. A quorum was
not present at the meeting and so the
Page 5
AUC Update

Volume 4, Number 3
April 8, 2016
Page 6
eligibility inquiries and responses;
remittance advices; and acknowledgments.
While the rate of electronic claims was high
for both Minnesota clinics and a national
benchmark (greater than 92% for both),
rates of Minnesota eligibility and remittance
transactions were slightly higher than
comparable national averages. (For more
information, see the presentation used at
the March 8 Operations meeting, with the
other meeting materials at:
http://www.health.state.mn.us/auc/mtgdoc
s/2016/ops030816mtgmat.pdf)
premium payment grace periods, and related
information from health plans to providers.
Results of recent “AUC customer satisfaction
survey.” Each year MDH conducts a survey
of the AUC to obtain opinions about its work
with the Committee and areas for possible
improvement. The survey was completed
recently, with the 60% of the AUC giving
MDH a grade of “excellent” and 40% a grade
of “very good.” Similarly, 2/3 of the AUC
ranked MDH as exceeding expectations in its
overall contributions to the AUC mission and
goals, while 1/3 felt that MDH met
expectations. (For more information, see
the presentation used at the March 8
Operations meeting, with the other meeting
materials at:
http://www.health.state.mn.us/auc/mtgdoc
s/2016/ops030816mtgmat.pdf)
The TAG met on March 21 and continued work
from a previous meeting to develop best
practices for using the 835 remittance advice
transaction for recoupment of overpayments to
providers. The TAG will complete its best
practices development at its next regularly
scheduled meeting on April 18.
The Eligibility TAG met March 23, 2016 to
review the proposed new guide and to draft
comments to submit on behalf of the AUC. The
TAG will complete its review and development
of draft comments at its next meeting scheduled
for April 27. The TAG will then forward its
comments to AUC Operations for a final review
and approval to submit to X12 to meet a
deadline of May 9, 2016.
EOB/REMIT TAG
MEDICAL CODE TAG
The MCT met on March 10 to review proposed
changes to the 837I and 837P companion guides
and to discuss an SBAR regarding “Intensive
Outpatient Mental Health Program for Pregnant
and Postpartum Women with Children ages 05.” The TAG is next scheduled to meet on April
14.
ELIGIBILITY TAG
EXECUTIVE COMMITTEE
The Accredited Standards Committee (ASC) X12
recently announced that it is seeking public
comments regarding a proposed new “ASC X12
Premium Payment Grace Period Notification
(271) Implementation Guide (007030X344).”
The Implementation Guide describes the use of
the ASC X12 Eligibility, Coverage or Benefit
Information (271) transaction set for reporting
Health Insurance Exchange (HIX) Premium
Payment Grace Period, other (non-HIX)
The Committee met briefly via phone and
Webex only on March 7 to discuss updates and
to review plans for the March 8 Operations
meeting. The Executive Committee meeting on
April 4 was canceled due to a light agenda, and
the Committee is next scheduled to meet on
May 2.
TAGS THAT DID NOT MEET IN MARCH 2016
•
•
•
Claims DD
Acknowledgments
ACO Data Analytics
AUC Update
Volume 4, Number 3
National News
ASC X12 announces public comment
period for HIX enrollee grace period
notification implementation guide
The national Accredited Standards Committee
X12 (ASC X12) recently announced the
availability of a new implementation guide, the
Premium Payment Grace Period Notification
(271) (007030X344), for public review through
May 9, 2016. The Guide provides the
transaction specifications to be used when
meeting federal notification requirements for
terminating the coverage of Health Insurance
Exchange enrollees who are receiving advance
payments of premium tax credits (APTC). The
federal coverage termination requirements
include:

allowing APTC enrollees a three month grace
period before terminating coverage due to
nonpayment of premiums;

requiring that the Qualified Health Plan
issuer (QHP - insurer) must notify providers
April 8, 2016
Page 7
that may be affected by the enrollee’s
premium payment grace period that an
enrollee has lapsed in his or her payment of
premiums.
In the absence of an applicable national
Accredited Standards Committee X12 (ASC X12)
transaction, the AUC adopted and published
best practices for notifying providers of the
grace period described above. X12’s new guide
describes the use of the ASC X12 Eligibility,
Coverage or Benefit Information (271)
transaction set for reporting Health Insurance
Exchange (HIX) Premium Payment Grace Period,
other (non-HIX) premium payment grace
periods, and related information from health
plans to providers.
The AUC Eligibility TAG is reviewing the X12
draft implementation guide to prepare
comments on behalf of the AUC Operations
Committee to submit to X12. Following the
TAG’s review and any recommendations, the
proposed comments will be submitted to AUC
Operations for additional review and a vote
prior to being forwarded to X12.
The draft implementation guide is available for
download at http://forums.x12.org. It is
provided for the purpose of public review and
cannot be used for any other purpose without
permission from ASC X12.
Unless and until the X12 guide is adopted as an
industry standard, AUC members and other
stakeholders are encouraged to use the AUC
best practices for notifying providers of
enrollees whose insurance premium payments
have lapsed.
AUC Update
Volume 4, Number 3
April 8, 2016
Page 8
AUC March- April 2016 Meeting Calendar
AUC meetings currently scheduled for April and May 2016 are listed below. For more information,
please see the AUC calendar page (http://www.health.state.mn.us/auc/calendar.htm).
Date/Time
Event
Location
April 14
9:00 am 12:00 pm
Medical Code TAG Meeting
Medical Code TAG Meeting Information
HealthPartners-Bloomington
8170 Building, 1st Floor - St.
Croix Room
April 18
1:00 pm 2:30 pm
EOB/Remit TAG Meeting
EOB/Remit TAG Meeting Information
Teleconference & WebEx only
April 27
2:00 pm 4:00 pm
Eligibility TAG Meeting
Eligibility TAG Meeting Information
Teleconference & WebEx only
May 2
8:30 am 10:30 am
Executive Committee Meeting
Executive Committee Meeting Information
HealthPartners-Bloomington
8170 Building, 1st Floor - Walnut
Room
May 12
9:00 am 12:00 pm
Medical Code TAG Meeting
Medical Code TAG Meeting Information
HealthPartners-Bloomington
8170 Building, 1st Floor - St.
Croix Room
May 16
1:00 pm 2:30 pm
EOB/Remit TAG Meeting
EOB/Remit TAG Meeting Information
Teleconference & WebEx only
May 25
2:00 pm 4:00 pm
Eligibility TAG Meeting
Eligibility TAG Meeting Information
Teleconference & WebEx only