Steve Bennett, Vice President, Workers' Compensation Programs for the American Property Casualty Insurance Association ("APCIA"): APCIA supports the proposed new Data Element Number ("DN") to EDI claimm reports.  The new DN will hopefully streamline determinations of timeliness in states such as Indiana and reduce the amount of reporting disputes. APCIA, however, is concerned with implementation as the new DN will require IT involvement and computer programming changes and possible file expansion to accomadate the new data elements.  Accordingly, we would request that the IAIABC provide an adequate implementation period for the new DN.  We would suggest an implementation period of one year.  Thank you.

Steve