While I certainly support the goal of simplicity, I hope that in its
interest the work group does not create a form which allows an entity to
avoid completing the assessment work of why they will not be in compliance
and how they plan to attain compliance. This is one the key reasons some
entities will not be ready - they have not had a adequate plan, budget, or
resources for readiness in comparison to their peers in the industry.
The form needs to be detailed enough to provide the NCVHS with summary data
of the "why" and should require the entity to provide enough detail that it
is evident they have created a reasonable plan of compliance.
I am a realist - I know there will be no army of reviewers available to
review the plans - but it should be more than a paperwork exercise.
Deborah A. Lelinski
IDX/LastWord HIPAA Program Manager
206.689.0967
[EMAIL PROTECTED]
www.idx.com
"Price,
Carolyn" To: David Blasi
<[EMAIL PROTECTED]>, [EMAIL PROTECTED]
<Carolyn.Pric cc: [EMAIL PROTECTED]
[EMAIL PROTECTED]> Subject: RE: Transaction Delay Question
01/15/2002
09:09 AM
David: A WEDI task force is completing work on a form recommended to be
used to file for a delay. Once completed, the recommendations must be
approved by the WEDI Board, and then -- hopefully-- by CMS. Lots of folks
have been working on this form, and the draft form is VERY SIMPLE to
complete. At this point, it is my understanding that each entity would be
responsible for filing their own compliance plan. I'll bring that
question
up in our conference call this week, and CMS will ultimately have to decide
that one, but I think each entity will have to file for themselves. If the
WEDI form is approved, it will be quite simple to complete in about 10
minutes MAX. With regard to the question of whether a compliant payor will
have to file for a delay due to receiving non-compliant transactions from
providers who have filed for delay--that question is still pending with
CMS,
and will be answered in a FAQ as soon as possible. Carolyn Price
-----Original Message-----
From: David Blasi [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, January 15, 2002 8:53 AM
To: [EMAIL PROTECTED]
Cc: [EMAIL PROTECTED]
Subject: Re: Transaction Delay Question
I'm assuming that those entities moving forward would still file a plan
for the extension. Obviously it will be a good plan, because you're in
effect saying "Done". But, this will allow for correcting
implementation problems, working with entities that are still using
non-standard, etc. I guess my point is that unless you have the ability
to not do business with certain entities and cut off all non-compliant
entities, you will have to file a plan for the extension.
Also, I would propose to the group (HHS representatives mostly) that
there should be an option for a mass filing for multiple plans. For
example, a service provider could file on behalf of all its client
plans. Similar to pension plan volume filers.
>>> "Jan Root" <[EMAIL PROTECTED]> 01/15/02 10:23AM >>>
Cynthia
I'm with you. The payers here in Utah who see a business advantage in
the HIPAA
transactions are going ahead with their original schedules for
implementation by October
2002. The reality is that they may not make that deadline for all the
transactions but
they're certainly going to try.
We tend to get focused on the problems with HIPAA but in the larger
scheme the HIPAA
transactions, flawed as they are, make good business sense. All
initial implementations
are flawed but if we waited until they were perfect we'd never get
anywhere!
Jan Root
Cynthia Korman wrote:
> Major payers who are farther along in their preparations will not
> necessarily want to delay. Or, their project plan for
implementation
> (required for the application to delay) could call for a phase-in of
the
> standards - they may want to stay "on schedule" with one or several
large
> providers with whom they have a good relationship and with whom they
want to
> start working directly rather than through a clearinghouse...or, they
may
> want to add support for a new transaction (Claim Status? 278?) as
part of
> an administrative cost-cutting plan, and so may want to stay
"on-schedule"
> with providers or clearinghouses who are also "on-schedule"...
>
> Individual "transaction senders" sharing with their big partner
"transaction
> receivers" information re: how they're addressing the delay option
could
> give logic to the whole thing...provide for good planning and
execution...
>
> Cynthia Korman
>
> ----- Original Message -----
> From: "Scott Sallyards" <[EMAIL PROTECTED]>
> To: <[EMAIL PROTECTED]>
> Sent: Tuesday, January 15, 2002 9:28 AM
> Subject: Re: Transaction Delay Question
>
> > Can anyone tell me if they think that this issue is industry wide,
now
> that
> > organizations can apply for a delay? Will the payors accommodate
the needs
> > of the providers (even though it is the providers responsibility).
I am
> > working with some providers and we trying to determine when will be
the
> best
> > time to flip the (transaction) switch.
> >
> > Scott
> >
> > ----- Original Message -----
> > From: Christopher J. Feahr, OD <[EMAIL PROTECTED]>
> > To: <[EMAIL PROTECTED]>
> > Sent: Sunday, January 13, 2002 10:12 AM
> > Subject: Re: Transaction Delay Question
> >
> >
> > > Until the deadline (any payor's deadline), that particular payor
can
> > > legally refuse to conduct a TX as standard even if the provider
requests
> > > that it do so. It certainly doesn't HAVE to refuse, but it can.
So the
> > > provider's options are exactly the same as they are today...
figure out
> > how
> > > to create the format that the payor WILL accept directly or go
through a
> > > clearinghouse. The costs for both options would have to be borne
by the
> > > provider... right up until the Payor's compliance deadline.
After that,
> > if
> > > that payor is still not ready and still requires a CH to
translate std.
> to
> > > proprietary, then the PAYOR will have to pay for the provider's
> > translation
> > > service.
> > >
> > > (keeping track of this looks like a major pain for the CH)
> > > -Chris
> > >
> > > At 08:22 PM 1/9/02 -0500, Paul Costello wrote:
> > >
> > >
> > > >What are the business implications of the following scenario
that
> occurs
> > > >on October 17, 2002:
> > > >
> > > >I am a health plan and I already filed for the extension (I only
have
> the
> > > >capability to accept non-standard formats).
> > > >
> > > >One of my trading partners (Provider ABC) purchased a whole new
health
> > > >information system that is 100% HIPAA compliant and only has
the
> ability
> > > >to conduct electronic transactions in the HIPAA standard
format.
> > > >
> > > >Since I (as the health plan that filed for the extension) can
not
> accept
> > > >standard transactions yet, and my trading partner (who just
purchased a
> > > >HIPAA-compliant HIS) can only send standard transactions, what
happens?
> > > >
> > > >Am I, as the health plan who can not accept standard
transactions,
> > > >responsible for routing those transactions through a
clearinghouse, or
> is
> > > >it the responsibility of the provider? What other solutions
exist?
> > > >
> > > >It seems like this situation, and many variations like it, will
become
> > > >problematic after October 16, 2002.
> > > >
> > > >Any thoughts are appreciated.
> > > >
> > > >Thanks,
> > > >Paul
> > > >
> > >
>**********************************************************************
> > > >To be removed from this list, go to:
> > > >http://snip.wedi.org/unsubscribe.cfm?listsiness
> > > >and enter your email address.
> > >
> > > Christopher J. Feahr, OD
> > > http://visiondatastandard.org
> > > [EMAIL PROTECTED]
> > > Cell/Pager: 707-529-2268
> > >
> > >
> > >
**********************************************************************
> > > To be removed from this list, go to:
> > http://snip.wedi.org/unsubscribe.cfm?list=business
> > > and enter your email address.
> > >
> > >
> >
> >
> >
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> > and enter your email address.
> >
>
>
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