We have a high cost estimate for implementing data element N407 (Country Subdivision Code) in the HIPAA 5010Version and would like to understand the rationale and original intent for adding this data element.  Please provide the purpose and who will be benefiting from the use of this data element.  Even as an entity that has many person and non-person addresses outside the United States, we currently don't see a benefit or use of this data element in our provider or payer processes.

Here, below, is some background information that we've been able to obtain or glean:

* An X12 DM for v4020 was approved in 1998 for addition of Country Subdivision Codes, referencing ISO 3166 Part-2. 

    ** X12 reps (Laurie Burckhardt and Gail Kocher) were unable to locate the original DM in order to state the original intent and purpose of adding the data element.

* The situational rule for Country Subdivision Code data elements in v5010 TR3's specifically says that the subdivision code is required in data element N407 if the country (non-US and non-Canada) identified in data element N404 has Country Subdivision Codes.  Many countries "do" have subdivision codes (e.g., Germany and England).

* Data element N407 applies to a wide range of postal addresses (organizational addresses, provider addresses, subscriber addresses, patient addresses).

     ** Previous answers to our email queries state (in part) that, "The reporting of a subdivision code for a country other than US and Canada, e.g. Italy in N402 in 005010 is out of compliance with the X12 standard and implementation because the Code Source available in N402 does not include the subdivisions of Italy and the situational rules for N402 and N407 require it be reported in N407 and require it not be reported in N402."

         *** The problem with this answer, is that N407 is not tied to N402 (State or Province if U.S. or Canada), instead the v5010 TR3's situational rule ties N407 usage to whether the N404 (Country Code) has subdivisions.

* Strict compliance with the letter of HIPAA v5010 guides (834, 271, 837) requires the use of Country Subdivision Codes for any non-US and non-Canada country that is identified in data element N404 which has ISO 3166 subdivision codes.  However, because the DM was approved in 1998 for X12 v4020, and since X12 reps don't appear to be able to access the approved DM, we don't know the original intent for use of the codes.

Could you help us, and the broader industry, understand the intent, purpose, and use of this data element in the TR3’s?  If there is no known or documented reason for N407 (Country Subdivision Code), we recommend that X12 remove this situationally required data element.