Section D of the ASCA compliance extension form specifies a timeframe for testing not later than April 16, 2003. Can you provide a definition of testing, and does it relate to all transactions?
ASCA requires that testing begin no later than April 2003. The law itself did not specify what type of testing, (e.g. internal, external, final with trading partners, all transactions, or just one, etc.) HHS interprets this to mean the date requested on the extension form as the date when internal system testing begins for the first transaction the covered entity will test. However, some covered entities will need to begin their external testing sooner than others, especially those that have many trading partners or are implementing many of the transactions. We encourage all covered entities to begin testing as soon as possible.
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