Compliance Alert - New resolution establishes e-invoicing key components in the healthcare sector

The Ministry of Health and Social Protection of Colombia has announced the publication of Resolution 2275/2023. This resolution establishes the Single Regulatory Resolution of the Individual Registry of Provision of Health Services - RIPS and includes support for the Electronic Bill of Sale (FEV) in health. Additionally, Technical Annexes 1 and 2 have been incorporated as integral components.

• Technical Annex 1: Includes the technical specifications and data structure for the correct generation of RIPS for the single validation process, as well as the characteristics that the RIPS data must meet in its relationship with the electronic sales invoice;
• Technical Annex 2: Presents the additional data fields in XML format for the generation of the electronic sales invoice for the health sector, and its main function is to articulate the invoice information with the Individual Record of Provision of Health Services.

The objectives of this resolution are:

• To extend the implementation period of the FEV in the health sector;
• To compile the operational standards related to the electronic sales billing and the RIPS as support for these.

Additionally, the technical annexes are updated to operational needs, in harmony with the provisions of Technical Annex 1.9 DIAN (Resolution 165/2023).

Resolution 2275/2023 applies to entities that must send or receive RIPS data in the terms established in Resolution 1036/2022, specified below:

• Health service providers (Health Service Providing Institutions, independent professionals, and patient care transportation);
• Health technology providers;
• Other entities that, within the framework of their legal functions, must deliver the data from the Individual Registry of Provision of Health Services – RIPS to the General Health Social Security System (entities with a corporate purpose other than the provision of health services and organizations that carry out pilots or research studies associated with the provision or provision of health services and technologies);
• Entities responsible for payment: Health-promoting entities, adapted entities, territorial entities, occupational risk managers in the health component, the National Health Fund for Persons Deprived of Liberty, and the administrators of the Special and Exception regimes, when they operate as payers of services and technologies to providers or suppliers;
• Other payers: Insurance companies authorized to offer Mandatory Traffic Accident Insurance – SOAT policies and entities that offer voluntary health plans;
• The Administrator of the Resources of the General Health Social Security System (ADRES).

RIPS is the data set containing information related to providing health services and technologies to users. It is used to provide health services and technologies and their billing, and for management, regulation and control processes, which are generated, validated, and sent as support for the sales invoice by electronic billers in the health sector. For the generation and validation of RIPS, these must be transmitted in JSON (JavaScript Object Notation) format.

The data required by the RIPS is:

• Transaction data;
• User data;
• Health services, technologies, and invoiced values data, such as:
  • Consultation data; o Procedure data;
  • Emergency data with observation;
  • Hospitalization data;
  • Newborn data;
  • Medication data;
  • Data from other services.

Electronic billers in the health sector must include the following information in individual and separate fields to meet the specifications of UBL (“Universal Business Language”) standards in XML format, as provided by the DIAN.

• Health service provider code;
• Payment methods;
• Coverage or benefit plan;
• Contract number;
• Policy number;
• Co-pay;
• Moderator fee;
• Shared payments in voluntary health plans;
• Advances;
• Start date of the billing period.

The electronic sales invoice, electronic equivalent document (record machine ticket with POS system), credit and debit notes, and other electronic documents, transmitted with the electronic validation document to the entity responsible for payment or another payer, must be sent to the Ministry of Health and Social Protection, for traceability of the sales invoice for health services and technologies.

The data related to the identification of users and the administrative and assistance details of health services and technologies must correspond with the RIPS.

Electronic billers in the health sector have 22 business days, counted from the electronic sales invoice issuance date, to file the approved invoice and RIPS with the entities responsible for payment or other payers by the Ministry's unique validation mechanism.

The Ministry of Health and Social Protection has launched an electronic billing microsite on its website. This platform allows users to access regulatory information, frequently asked questions and technical documentation related to electronic invoices.

The transition schedule for the implementation of the RIPS to support FEV in health and the start of operation of the single validation mechanism platform is described in the resolution:

• As of 1 April 2024, obligated entities must deliver the RIPS corresponding to the health services and technologies provided, and invoiced as of this date, in accordance with the resolution and the technical annexes.
• Health service providers, entities responsible for payment, and other payers will have time until 30 September 2024 to send the RIPS for care provided before 1 April 2024, in accordance with the frequency with which they are sent during the operation.