Page 210 of the ANSI 837 implementation guide indicates that in the CR6 data segment (Loop 2300 - Claim Information), CR615 & CR616 are situational and CR617 is required.
But the third syntax note for this segment is: P151617, which means that if any of the CR615, CR616 or CR617 are present, then the others are required. Owing to this syntax note, since CR617 is required, CR615 and CR616 become required even though they are misleadingly indicated as situational.
Our main problem is with CR616 (Most Recent Inpatient Stay dates). In our home health agencies, for most patients this data is not applicable at all, or it is not readily available.
But since this element is required, I tried using a dummy date range like "00000000-00000000" or "99999999-99999999", but the test claims were rejected because of invalid dates. Finally, I settled on "19000101-19000101", which was accepted by our intermediary.
However, this band-aid is not the solution to this issue. I think that the syntax note needs to be suitably modified.