The X12 advisory committee—which helps formulate standards for the insurance industry— has recommended changes that will allow standard health insurance claims forms to record unique device identifiers (UDIs). Putting UDIs in claims forms has widespread support.

Hospitals, providers, payers, and patient advocacy groups welcome the recommendation, says Ben Moscovitch, who manages health information technology at The Pew Charitable Trusts. “This is a common-sense approach to improve patient safety and reduce costs.”

Pew has conducted studies to demonstrate the financial costs of omitting UDI data on claims forms.

“Stakeholders across the healthcare system have called for the addition of device identifiers to claims,” Moscovitch says. “Hospitals, health plans, clinical societies, public health groups, patients and members of both parties in congress support adding device information to claims.”

Next steps

The committee’s recommendation is a critical first step, but many more remain before the changes can be implemented. What is key, says Moscovitch, is that these stakeholders do not miss this window of opportunity. “Claim forms are updated infrequently—only every decade or so.”

Yesterday’s announcement marks the start of a public comment period on the proposed revisions to include UDIs in claims forms. X12 must finalize its recommendations, which will then be reviewed by other advisory committees, and eventually presented to CMS to develop the final rules. That process could take a year or more.

After the proposal is finalized, several other steps remain. Moscovitch says those include an advisory committee review, and rule-making from CMS to adopt the changes. “After rule-making, there is also an approximately two-year implementation period for those changes.”

All told, the new proposed modifications from X12 may not be fully implemented until about 2021.

Implementing UDIs in claims forms

Implementing UDIs in claims forms will not be a simple task. Issues will include figuring out how to capture or document UDI at the point of care. “This is critical to ensure that UDI can then be used in various applications. For example, documenting UDI in the EHR will then enable UDI to be used in downstream application such as in claims or registries.”

Starting in 2018, the EHR certification criteria will include a field for the UDIs of implanted medical devices, so EHRs will have the capability to capture UDI data before the next version of the claim documents are implemented. Moscovitch says hospitals are also starting to use UDI information for supply-chain purposes.

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