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The Designated Standard Maintenance
Organizations Process


  What is the DSMO?

Designated Standard Maintenance Organizations (DSMO)

  • Organizations named by the Secretary (HHS) under HIPAA in 162.910(a) to
    • Maintain standards adopted under HIPAA
    • Receive and process requests to adopt new standards or modify existing standards
  • Member Organizations are standards development organizations (SDOs) and data content committees
    • Accredited Standards Committee (ASC) X12
    • Dental Content Committee of the American Dental Association (DeCC)
    • Health Level Seven (HL7)
    • National Council for Prescription Drug Programs (NCPDP)
    • National Uniform Billing Committee (NUBC)
    • National Uniform Claim Committee (NUCC)

Process for modification of existing standards and adoption of new standards must include:

  • Open public access
  • Coordination with other DSMOs
  • An appeals process for each of the following, if dissatisfied with the decision on the request:
    • The requester of the proposed modification.
    • A DSMO that participated in the review and analysis of the request for the proposed modification, or the proposed new standard.
  • Expedited process to address content needs identified within the industry, if appropriate.
  • Submission of the recommendation to the National Committee on Vital and Health Statistics (NCVHS)

Process details defined through a Memorandum of Understanding (MOU)

MOU defines Guiding Principles

  • Public access (single point of entry)
  • Timely review of change requests
  • Cooperation and communication
  • Consider all viewpoints
  • Evaluate impact of change requests
  • Maintain a national perspective
  • Conform to legislation


  What does this mean in English?

Public access portal for the submission of requests to:

  • Modify existing standard transactions adopted under HIPAA
  • Request new standard transactions for adoption under HIPAA
  • e.g. new business need or data need
  • e.g. data needs change from current transaction

Submission via Web or Paper

  • Web-based reviewed just below
  • Paper-based reviewd at end of this page under resources


  How do I submit a change request?

Web-based process

  • Requester logs in to web site requires creation of a login ID
    • Captures name, email address and contact information
    • Needed in the event that additional clarification of request is needed during the review process
    • Information available only to DSMO Secretary and Administrator, EXCEPT for email address, which is viewable on the public Web site. Nothing else distributed to DSMO members.
  • Communication with requester generally occurs through the DSMO Secretary

DSMO Figure 1

Figure 1 - Create a Log in ID Step 1

DSMO Figure 2

Figure 2 - Create a Log in ID Step 2

Step-by-step process

  1. Select request type
DSMO Figure 3

Figure 3 - Identify the Request Type

  1. Enter Business Reason for change
DSMO Figure 4

Figure 4 - Identify the Business Reason for the Change Request

  1. Provide suggested revision to address the change
DSMO Figure 5

Figure 5 - Identify the Suggested Solution for the Change Request

  1. Receive DSMO Change Request (DSMO CR) ID #
DSMO Figure 6

Figure 6 - Change Request Number Provided

  1. Complete questionnaire form (X12N requests)
•  Identify additional guides that may be impacted by CR DSMO Figure 7

Figure 7 - Other Implementation Guides Affected

•  Provide information relative to previous change request
1.  CMS FAQs reviewed Yes/No
2.  Existing DSMO CRs reviewed Yes/No
3.  New request Yes/No
4.  Provide any related DSMO CR numbers DSMO Figure 8

Figure 8 - Research Conducted

•  Identify version, key page numbers and sections of the guide DSMO Figure 9

Figure 9 - Specific Items Impacted in Implementation Guide

•  Identify any specific areas and/or specialties of health care impacted by the request DSMO Figure 10

Figure 10 - Other Health Care Areas Impacted

•  Provide Subject Matter Expert and Alternate Contact information DSMO Figure 11

Figure 11 - Requester Contact Information

•  Additional information regarding:
•  X12 group participation
•  X12 groups contacted
•  Other industry groups contacted
•  Information provided by any of the above DSMO Figure 12

Figure 12 - Other Input Received


  What happens next?

DSMO Change Request Process

  • Allows DSMO members to opt-in or opt-out of a change request
  • Review Process generates batches on a monthly basis
  • DSMO Review is a 90-day cycle
    • Details follow below
  • DSMO members may request one 45-day extension
    • Details follow below
  • Requester or DSMO member may submit an appeal to the DSMO response
    • Details follow below

DSMO Process Flow 90-day Batch Cycle

DSMO Figure 13

Figure 13 - 90-day Batch Cycle Flow

DSMO Response Categories

According to DHHS, necessary items include:

  1. Modifications necessary to permit compliance with the standard/law.
    1. Something in the adopted standard or implementation specification conflicts with the regulation.
    2. A non-existent data element or code set is required by the standard. (removal of data content that is not supported by the healthcare industry any longer)
    3. A data element or code set that is critical to the industry's business process has been left out.
    4. There is a conflict among different adopted standards
    5. There is an internal conflict within a standard (implementation guide).
  2. Modifications.
    Classified as additions or deletions of data elements, internal code list values, segments, loops; changes in usage of segments, data elements, internal code list values; changes in usage notes; changes in repeat counts; changes in formatting notes or explanatory language that do not fall into Category A.
  3. Maintenance.
    Classified as items that do not impact the implementation of the transaction. Items classified as Maintenance will require no further DSMO actions. Items are to follow the SDO process.
  4. No Change.
    Classified as items that the implementation guides do meet the needs requested, or did go through the consensus building process originally to meet need. May request follow up by the submitter for further action.
  5. DHHS Policy.
    Classified as items that require follow up by the Department of Health and Human Services in regards to the Final Rule.
  6. Withdrawn by Submitter.
    Classified as items that have been removed from Change Request System consideration.
  7. Appeal.
    Classified as items where the DSMOs did not reach consensus on response and will follow the appeal process.
  8. Industry Comment Request Process.
    Classified as items that require comments from the industry to determine consensus.
  9. Recommendation for adoption of new/modified HIPAA standard.
    Classified as items that result in the recommendation to the National Committee on Vital and Health Statistics for the adoption of a new/modified HIPAA standard. Examples might include a request for a new transaction, or a new version or release of an already-named standard for a given transaction(s).
  10. Out of DSMO Scope.
    Classified as items that are not in the scope of the DSMO. An example is change requests for modifications to transactions not named in HIPAA.

DSMO Appeal Process

DSMO Figure 14

Figure 14 - DSMO Appeal Process Flow

DSMO Appeal Process: Appeal Denied

DSMO Figure 15

Figure 15 - DSMO Appeal Process: Appeal Denied Flow

DSMO Appeal Process: Appeal Upheld

DSMO Figure 16

Figure 16 - DSMO Appeal Process: Appeal Upheld Flow

DSMO Appeal Process Response Categories

  • Appeal Outcome Available Soon
  • Appeal Withdrawn
  • Appeal Upheld
  • Appeal Denied
  • Appeal Remanded



Web Sites

    ASC X12    
ADA DeCC    

To Submit Change Requests via Mail or Fax

    Transaction Type     Mailing Address     Fax Number
    Retail Pharmacy Transactions         National Council for Prescription Drug Programs    
240 East Raintree Drive
Scottsdale, AZ 85260-7518
    (480) 767-1042
    Attachment Booklets     Health Level Seven, Inc.
3300 Washtenaw Avenue
Suite 227
Ann Arbor, MI 48104
    (734) 677-6622
    All Other Transactions     Washington Publishing Company
10940 NE 33rd Place
Suite 204
Bellevue, WA 98004
    (775) 239-2061

Download the Presentation



The Designated Standards Maintenance Organizations (DSMO) have created a presentation "Understanding the HIPAA Processes" to provide information on the HIPAA transactions, code sets, and operating rules processes under HIPAA. The presentation was developed to satisfy an industry need to have in one concise document the process of how to request changes to HIPAA mandated standards.

The presentation is available at or directly.

The DSMO includes three American National Standards Institute (ANSI) Accredited standard development organizations - Accredited Standards Committee (ASC) X12, Health Level Seven (HL7) International, and the National Council for Prescription Drug Programs (NCPDP), and three data content organizations, the American Dental Association (ADA) Dental Content Committee (DeCC), National Uniform Billing Committee (NUBC), and National Uniform Claim Committee (NUCC). The DSMO reviews change requests to the HIPAA designated standards and requests for new standards and code sets to be adopted.