Last week, the work of GNYHA member facilities to comply with the Privacy Rule of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) came to fruition on the compliance date of April 14, 2003. While GNYHA members report successful implementation, many note the need for ongoing compliance monitoring and fine-tuning of operations. To provide support, GNYHA's HIPAA Privacy Workgroup will continue to meet, and GNYHA will maintain its efforts to advocate for modifications to the Privacy Rule and monitor its enforcement. GNYHA will continue to advocate for a modification to reduce the administrative burden of the Privacy Rule's accounting of disclosures requirement, and will solicit member comments on the interim enforcement rule for HIPAA's Privacy, Security, and Transaction Set Rules released by the U.S. Department of Health and Human Services on April 17. Efforts on the HIPAA Transaction Sets will continue in anticipation of the October 16, 2003, compliance deadline.

Because of strong member concerns regarding implementation, GNYHA recently sent a letter to the Centers for Medicare & Medicaid Services (CMS) asking CMS to address these implementation concerns and their impact on hospitals' and nursing facilities' cash flow. For the Security Rule, GNYHA will increase its efforts to support member compliance with these regulations and is assessing opportunities to share the costs of developing compliance strategies.