HIPAA Code Sets

It identifies six outcomes (benefits) from the RAND study: more accurate payments for new procedures, fewer rejected claims, fewer improper claims, better understanding of new procedures, improved disease management, better understanding of health conditions and health care outcomes, and harmonization of disease monitoring and reporting worldwide.

The first four are measured and monetized. The fifth is measured but not monetized. The last is not measured or monetized.

Mostly the effects are just asserted with references to sources.

The analysis uses two prominent studies with url links, uses other studies when needed, and established a cross-agency working group. The working group seems to be an unusual but clever way to go about benefit-cost analysis and does a much better job than other RIAs.

A range of benefit estimates is provided, based on a review of the two primary studies and supplemental information from others.

The current system is running out of room for new codes and probably leads to inaccuracies. Since HHS designed the previous system, it's up to HHS to change it.

Though implicit in the above explanation, it is not spelled out in any detail.

Mostly just assumed/asserted, but plausible given the above entry.

Uncertainty is indirectly acknowledged in the calculation of ranges for benefits, but the existence of problem(s) is taken as certain.

The analysis lists the alternatives considered, gives more detail to them in the regulatory flexibility analysis, and briefly discusses their costs or inefficiencies. Examples include: continue to use current system, delay introduction of new system, use other coding systems, and wait until next generation system is developed.

The analysis discusses options that are moderately different. The options are alternative federally required coding sets, but not alternatives to federally required coding sets.

A brief discussion rules out alternatives based on effectiveness, but there is not much in-depth analysis or calculation of the amount of benefit the alternatives would produce. The discussion does note a GAO study that was critical of one of the options.

The analysis never really establishes a baseline, but one can gather the assumption that it is the current coding system. It assumes no one will come up with a solution, which might be reasonable, but not much effort is spent justifying it.

The analysis quantifies implementation/compliance costs for federal government and private entities. It does not examine costs of alternatives. There's a reasonably thorough analysis of costs of the rule, but not of other options.

Seems pretty comprehensive; based on several previous analyses of costs undertaken by outside parties.

Costs are only extended to the providers and payers, but not to any effects to the actual patients themselves. That would have been very informative.

There are a few limited assumptions about how the change in coding categories might affect the size of costs or benefits. But there is no analysis of how the increased costs might filter through and affect behavior, or of any perverse behavioral consequences created by the adoption of the new classification system. All health care entities will be affected and they have to figure out a way to deal with the new codes; it doesn't talk about whether some will switch to other ways of using the codes and billing systems. In some areas the RIA briefly talks about productivity minutes lost, number of procedures affected, and person-year training time, but it is inconsistent and mildly informative.

Ranges are presented but not extensively justified. Brief reasons for some judgment calls are given.

The analysis dismisses alternatives with short arguments that they will not achieve benefits as large, or as soon, or may have higher costs. It only gives net benefits for the rule.

It asserts that it adopted the most cost-effective alternative, but does not calculate the monetized net benefits of the other options.

It estimates costs for different types of providers/suppliers, but not for patients.

The benefits presented are society-wide; the analysis sometimes identifies the particular part of industry where a benefit may occur.