The National Association of State Medicaid Directors (NASMD) sent a letter to the Centers for Medicare & Medicaid Services (CMS) to determine how the national health care reform law's National Correct Coding Initiative (NCCI) must be implemented.  In the letter, NASMD seeks guidance on how the rules will be applied to determine how they must compile their data to comply with its requirements.

From the letter: While considerable discussion has occurred surrounding the extent to which National Correct Coding Initiatives (NCCI) must be implemented, additional discussion and guidance around the statement “effective for claims filed on or after October 1, 2010” may be warranted. The Correct Coding Initiative edits, which are part and parcel to the CCI methodologies, are released quarterly. It will be important to understand if the intent of CMS is to edit claims against CCI in a “date sensitive” fashion, only applying the CCI edits for a particular quarter against a claims with a corresponding date that falls within that same quarter. If this is the intent, then Medicaid programs will have to prepare to edit claims “filed on or after October 1st” against NCCI files from previous quarterly releases. If this is not the intent, then CMS must identify the specific NCCI file they wish to use for editing purposes.

Full letter: Letter to CMS on National Correct Coding Initiative (PDF | 84.5 KB) 

National Association of State Medicaid Directors.  (2010).  Letter to CMS on National Correct Coding Initiative.  Kohler, A. and Steckel, C.