The 278 (x217) PWK02 segment (Additional Patient Information) allows for additional documentation to be electronically transmitted using the EL (EL: Electronic Only) in the PWK02. There is a usage note included with the EL that states “Use to indicate that the attachment is being transmitted in a separate X12 functional group.” Can the EL be used for non-X12 transactions? Medicare is requesting an interpretation of the use of EL as we are considering using a new mechanism, Electronic Submission of Medical Documentation (esMD) for providers to use to submit medical documentation to Medicare and Medicaid Review contractors. At this time the esMD program is not using an ASC X12 standard. Therefore, when reviewing the codes allowed in the PWK02 we do not see a valid option for sending esMD data.
The EL qualifier in the PWK02 element explicitly states “Use to indicate that attachment is being transmitted in a separate X12 functional group.” Therefore, it is not compliant with the 005010X217 TR3 to use the value of “EL” in the PWK02 and not send the attachment in a separate ASC X12 functional group. The 005010X217 does not support sending an attachment in an electronic format not transmitted in a separate ASC X12 functional group other than by email (EM) or fax (FX).
If you have a business need not supported in a published TR3, you may submit an ASC X12 change request for consideration in a future version of the TR3. Change requests are submitted at http://changerequest.x12.org/