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Back  RFI # 355: Min length of nm109 not met

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Submitter

Janice Cunningham

Description

This issue was reported to a Medicaid as a non-compliance issue due to invalid length of NM109. The minimum length for NM109 is 2.

CLP*013067491*4*33176.29*0**MC*102005252536000*11*1
NM1*QC*1*TH*D****MR*1

I was told by the payer that they are reporting back what was submitted on the claim. When I explained that they had to meet the standards set forth in the IG they disagreed because they understand they have to report back exactly what was sent on the claim. When I directed them to the Gap Fill Policy contained in the document contained the link below. They stated this does not apply to them.

http://www.cms.hhs.gov/manuals/104_claims/clm104c22.pdf

My question, when the data contained on the submitted claim does not meet the IG standards what is the responsibility of the payer? Are they required to gap fill or can they be non-compliant is that situation?

Response

This issue is explicitly addressed in guide 004010X091. Section A.1.3.1.4 state "Trailing spaces should be suppressed unless they are necessary to satisfy a minimum length." Page 104 states that the minimum length of NM109 is 2 characters. While there is a requirement to report exactly what was submitted on the claim, there is also a requirement to meet the minimum length two characters. This is accomplished by space filling on the right to meet the minimum. Sending an NM109 containing only 1 character is not compliant with this guide.
Questions about HIPAA compliance should be addressed to askhipaa@cms.hhs.gov.
Submission 11/9/2005
Status Date 11/30/2005
Status F - Final
Primary References
Document 004010X091A1
SectionNM1
Page104
Set IDNM109
Loop2100
Segment Position030