The testing phase as described in H.R. 3323 is vague I'll agree, but if you
examine the industry consensus, add a little common sense and apply the
timelines for application development it should be clear that organizations
should start testing the last few transactions in April 2003 if you have any
expectation of meeting the October 2003 deadline for implementation. There
should be a new white paper just to educate decision makers that the only
thing the extension granted was the ability to be HIPAA compliant by October
2003 if you start right now!!!  The deadline extension gave people a false
sense of security that everything can be postponed for a while. This is
certainly not the case. In addition, the Privacy regulations are still
scheduled to go into effect April, 14, 2003. Wouldn't it be easier to
complete the testing efforts prior to the privacy guidelines than after?
I'm not confident that even a super-human effort by a highly sophisticated
test team could accomplish the level of testing required in six months.
There are too many other critical factors at work. The high possibility of
rework due to vague business requirements, the sheer magnitude of test cases
involved, the multiple test phases required and the scheduling complexity
for trading partner testing efforts in my mind would be unmanageable to say
the least. I'm sure we'll see...



Mark A Lott
CIO
HIPAA Testing, Inc.
480-946-7200

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