Article from PREFERRED Network News (PNN) September 2003, A PREFERRED Therapy Providers Newsletter

Small Provider HIPAA Update

Most of PREFERRED's network members have already implemented their electronic transactions systems for the October compliance date. For those of you who do not have electronic capabilities and plan to continue to bill Medicare using paper claims, you must meet the following "Small Provider" criteria:

- a “provider of services” (typically a Part A provider) with fewer than 25 full-time equivalent employees, OR
- a physician, practitioner, facility or supplier that's not a “provider of services” (typically a Part B provider or supplier) with fewer than 10 full-time equivalent employees.

Providers meeting the criteria will automatically have exempt status from the requirement of billing Medicare claims electronically: There is no action needed to be opted out, there is no waiver to sign, you may continue to bill using paper claims; however, PREFERRED strongly recommends that you consider the following:

- If continuing paper billing, document your decision to vary from the regulations in your HIPAA compliance manual.
- Continue to explore electronic options - have a system or service in mind in the event that it becomes a mandatory requirement to participate with certain private payors / healthplans.

The final rule, which was published August 15, 2003, can be found at:
http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/2003/pdf/03-20955.pdf