December 6, 2018
Nicholas L. Coussoule, Co-Chair, Subcommittee on Standards
Alexandra Goss, Co-Chair, Subcommittee on Standards
National Committee on Vital and Health Statistics
CDC/National Center for Health Statistics
3311 Toledo Road
Hyattsville, MD 20782-2002
Via: NCVHSmail@cdc.gov
RE: Draft Recommendations for the Predictability Roadmap
Dear Mr. Coussoule and Ms. Goss:
The Medical Group Management Association (MGMA) is pleased to submit the following letter in response to the request for comments on the National Committee on Vital and Health Statistics (NCVHS) “Draft Recommendations for the Predictability Roadmap,” published on August 24, 2018. We believe this roadmap is an important initial step toward improving the identification and implementation of administrative standards that will streamline communications between providers and health plans.
MGMA is the premier association for professionals who lead medical practice. Since 1926, through data, people, insights, and advocacy, MGMA empowers medical group practices to innovate and create meaningful change in healthcare. With a membership of more than 45,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures and specialties that deliver almost half of the healthcare in the United States.
The current process for developing and adopting new and revised administrative simplification standards, encouraging wide-spread use of the standards, and enforcing compliance with the standards is defective. Transitioning from one version of the X12 standards (4010 to 5010, 5010 to 7030) has been needlessly protracted with some federally-mandated standards still waiting to be promulgated. For example, the X12 275 electronic transaction has yet to be published, despite two statutory requirements and four separate letters sent by the NCVHS calling for its release. Many of the currently-mandated standards are being underutilized and health plans are increasingly driving physician practices to proprietary web portals and away from the efficient use of electronic data interchange.
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