David,
Thank you very much for your comments... I think we are getting to the core
of the issue as I see it. Your statement that "One of the fundamental
underpinnings for distinguishing between what is a claim and what is an
attachment is a global analysis of what information is used all the time --
or at least the vast majority of the time -- to process *all* claims or
encounters [in the entire healthcare industry]" raises a couple questions
for me:
1. Is the decision to use the needs of the *entire healthcare industry* as
basis for this a matter of law or of convention? And...
2. If we did decide to resolve the claim vs attachment question for each
discrete segment of the healthcare system, would we look at unique/special
groupings of providers or of payors?
The "vision world" has always felt (to me, anyway) like a "parallel
universe" and many transaction elements that appear to be "exceptions" with
respect to mainstream health payors are huge parts of the milieu that ODs
live in (and are presently at grave risk of drowning in). So I think the
real question is regarding how much benefit and true administrative
simplification our non-mainstream providers have a right to expect from
HIPAA. It is possible... perhaps likely... that emerging information
technology combined with all this HIPAA discussion will stimulate the
vision industry to "get its act together" re: national data standards. But
this is by no means certain. IT solutions are being developed now in the
Vision industry and some of them are brilliant... but they are all highly
proprietary.
Optometrists and their patients deserve equal protection under the law. To
accomplish this for them in a reasonable time frame, I believe our industry
will require reasonable deadlines combined with severe penalties (same as
everyone else needed). I respectfully take issue with your "floor, but not
a ceiling" statement about HIPAA, David. Each HIPAA Implementation Guide
seems to establish both a floor and a ceiling for a particular
transaction. The fact that our "routine claim" transaction looks different
from a dermatologist's "routine claim", should not remove ours from the
requirement to have a national standard applied to it. Retail pharmacy
encounters are also "different", but fortunately that industry bit the
bullet 20 years ago and created the NCPDP. Arguably, Vision is starting
"late" with this. But in our defense, we have a much uglier problem to
codify and a highly fragmented industry... with very little in-house IT
talent in most eyecare businesses.
Thanks again
Best regards,
Chris
At 09:56 AM 8/27/01 -0700, David A. Feinberg, C.D.P. wrote:
>Since a HIPAA-standard does not exist for the information normally
>found on a lab purchase order, it will not be legal after 10-16-02 for
>[VISION PAYOR] to receive that information electronically.
> <<Afraid I do not quite concur. Under HIPAA, a provider will not
>be allowed to send additional information to support a claim using a
>*HIPAA standard transaction*. HIPAA standard transactions represent a
>floor for the industry, not a ceiling. If the vision industry can
>establish an electronic standard for the information found in a lab
>purchase order, that may always be electronically sent in addition to
>the HIPAA standard claim transaction. In fact, if the vision industry
>can establish such an electronic standard using the same technology
>(i.e., HL7 ORU message with LOINC coding) as used for other
>forthcoming HIPAA attachments, then turning the vision industry
>standard into a HIPAA standard could be relatively straightforward.>>
>
>Information necessary for routine claim adjudication that cannot be
>placed into a standard "837 claim" or into one of the standard "claim
>attachments" (proposed by HL7 and the Claim Attachment Committee) will
>have to be sent to the vision plan or its exclusive business agent,
>via paper.
> <<Again, I do not completely concur. Of course, a provider may
>always elect to use paper to convey additional information. However,
>again, see my comments above about the HIPAA standard transactions
>representing a floor for the industry, not a ceiling.>>
Christopher J. Feahr, OD
http://visiondatastandard.org
[EMAIL PROTECTED]
Cell/Pager: 707-529-2268
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