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A number of carriers were fined recently for failing to accurately submit medical bill and payment data. One carrier was fined $15,000 for this violation. The submission of medical bill and payment data is governed by a complex set of regulations which includes the Labor Code, Division rules 134.800 - 134.808, the IAIABC EDI Implementation Guide, the Texas EDI Medical Data Element Requirement Table, the Texas EDI Medical Data Element Edits Table, and the Texas EDI Medical Difference Table.
James Madison could have been describing the laws governing the submission of medical bill and payment data when he wrote the following:
It will be of little avail to the people that the laws are made by men of their own choice, if the laws be so voluminous that they cannot be read, or so incoherent that they cannot be understood; if they be repealed or revised before they are promulgated, or undergo such incessant changes that no man who knows what the law is today can guess what is will be tomorrow.
James Madison, Federalist no. 62, February 27, 1788.
Given the complicated reporting standards and the lack of harm to any system participants from these alleged violations, the Division should consider taking a more collaborative approach with carriers rather than treating potential violations as an opportunity to collect a fine.