Cynthia,

HHS has a FAQ on this issue that clarifies the 834 transaction is not
required to be used for a self-insured employer to transmit enrollment
information to a TPA.  The following is the link:

http://aspe.os.dhhs.gov/admnsimp/q0041.htm

In addition, many of TM Floyd's clients that are health plans and insure
their employees have had their internal and external legal counsel review
this issue.  The responses were that the healthy plans were not required by
HIPAA legislation to send the 834 transaction to their Enrollment
Information System.  Of course, the health plan could send the 834
transaction to their Enrollment system if the plan wanted to implement the
834 transaction for the employees of the health plan.

Cynthia, you are not alone in your view of this subject since plans and
self-insured employers have all requested clarification.  Please feel free
to contact me if you would like to discus this issue in more detail.

Hope Furtado
Corporate Information Architect
TM Floyd & Company, Inc.
[EMAIL PROTECTED]
(800)780-1170 extension 129

> -----Original Message-----
> From: Cynthia Korman [SMTP:[EMAIL PROTECTED]]
> Sent: Wednesday, January 23, 2002 1:07 PM
> To:   [EMAIL PROTECTED]
> Subject:      Re: HIPAA EDI
> 
> Actually, I beg to differ with Rachel's opinion...the transaction rules
> have
> to be followed whether
> the transmissions are between or within covered entities - my
> understanding
> is that since an ERISA healthplan is defined as a covered entity, those
> that
> communicate membership to TPAs must do so via an 834.  Also, their TPAs
> must
> be prepared to handle standard transactions from providers that provide
> care
> to the ERISA plan's members.  Where am I off base?
> ----- Original Message -----
> From: "Rachel Foerster" <[EMAIL PROTECTED]>
> To: <[EMAIL PROTECTED]>
> Sent: Wednesday, January 23, 2002 12:38 PM
> Subject: RE: HIPAA EDI
> 
> 
> > Steve,
> >
> > >From your description of your company I doubt that HIPAA applies to it.
> It
> > doesn't appear to be a health plan, clearinghouse, or health care
> provider.
> > Thus, it would be my opinion that the format, etc. used by your company
> > would be one based on mutual agreement between you and whoever you're
> > exchanging the data with.
> >
> > Rachel Foerster
> > Rachel Foerster & Associates, Ltd.
> > Phone: 847-872-8070
> >
> >
> > -----Original Message-----
> > From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]]
> > Sent: Wednesday, January 23, 2002 11:03 AM
> > To: [EMAIL PROTECTED]
> > Subject: HIPAA EDI
> >
> >
> > So if I understand what everyone is saying correctly:
> >
> > [1] your business must have HIPAA EDI capability ready for any requests
> > that may occur.  That is required although you may not be required to
> use
> > it (Carriers, providers, etc. may have you continue to use paper, etc.).
> >
> > ----------
> > I as mentioned earlier my situation is interesting:
> > I work for an MGU (Managing General Underwriter) in the Self-Insured
> > market.  We work with TPAs, Brokers and Carriers but not directly to any
> > health organization nor hospital.   Currently our Carriers have no plans
> > nor requirements for us for HIPAA EDI.   Most of our TPAs and Brokers
> also
> > have no plans as of this time.
> >
> > We are working on building up our EDI capabilities ... but if we build
> it
> > will it be used?!?!  With this HIPAA mandate we were ready to move
> forward
> > but if the people we are communicating with are not we are put in a
> catch
> > 22 situation with compliancy.
> >
> > Sincerely,
> >
> > Steve Sklar
> > IT Manager
> > Majestic Underwriters, Inc.
> > Troy, Michigan
> > (p) 248.583.4488  x246
> >
> >
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