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Health Insurance Reform: Standards for Electronic Transactions

III. Analysis of, and Responses to, Public Comments on the Proposed Rule

In response to the publication in the Federal Register of the proposed rule on May 7, 1998, we received approximately 17,000 timely public comments. The comments came from a wide variety of correspondents including professional associations and societies, health care workers, law firms, third party health insurers, hospitals, and private individuals. We reviewed each commenter’s letter and grouped like or related comments. Some comments were identical, indicating that the commenters had submitted form letters. After associating like comments, we placed them in categories based on subject matter or based on the section(s) of the regulations affected and then reviewed the comments. All comments relating to general subjects, such as the format of the regulations were similarly reviewed.

This process identified areas of the proposed regulation that required review in terms of their effect on policy, consistency, or clarity of the rules.

We present comments and responses generally in the order in which the issues appeared in the May 1998 proposed rule.

General - Comment Period

A. Applicability

B. Definitions

C. Effective Dates and Compliance Dates

D. Data Content

E. Availability of Implementation Specifications

F. Proposed Requirements Stated in Each Subpart

G. Compliance Testing

H. Enforcement

I. New and Revised Standards

J. Proposed Impact Analysis

K. Regulatory Flexibility Analysis

L. Unfunded mandates

TABLE OF CONTENTS