Recently, the federal Centers for Rhledicare and Medicaid Services ("CMS"), the successor agency to the Health Care Financing Administration, published a "model compliance plan" for use by SNFs and other health care providers that will not be compliant with the HIPAA Electronic Health Care Transactions and Code Sets Rules before October 16,2002. CAHSA members that operate SNFs must submit the compliance plan to CMS no later than midnight on October 15, 2002. While this may seem to impose a substantial burden, it should be quite manageable if approached in the proper manner.
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