A pearl from the mud slinging - an issue worth discussing on the list.
William Kammerer said:
"Jonathan fails to elaborate precisely what HIPAA does that is out of
compliance with X12. Every valid HIPAA transaction set is also a valid
X12 transaction set. A careful reading of Jonathan's statement reveals
that he is merely saying their *implementation guide* is out of some
kind of conformance with an obscure X12 Technical Report ("Compliance in
X12" - X12C/99-197 - published in 1999).
The HIPAA implementation guides fairly well describe valid X12
transaction subsets. If the HIPAA IGs really are *wildly* out of
compliance with this vaunted Technical Report, then perhaps there's
something wrong with the latter and not with the HIPAA guides
themselves."
While part of what William says may be true, the fact of the matter
reveals something deeper. One of Foresight's more well known customers,
the Department of Defense, is in litigation over this type of issue -
implementation compliance to something produced by X12. I don't know if
it was a failure of EDISIM compliance checks or not, but I would guess
that EDISIM's compliance checking for implementations is a case of "free
advice" - and worth every penny (even though you pay for the tool).
Jonathan does have a point in his rebuttal to William - every HIPAA
transaction set may be a valid X12 transaction set, but not compliant
with X12's definition of Compliance with X12. DOD is in litigation over
compliance to X12 guidance on implementing the standards - that's a
fact.
Other members of this list may be better able to articulate the
particulars of the litigation. What I do know is that X12 has been
asked by the lawyers to make specific comments on the issues based on
DoD's claim to be "X12 compliant". If they (X12) can't answer the
question of what is compliant or not, in a concise way, then we all have
potential legal troubles, including HIPAA. The answers may prove
William right - the technical papers that X12 produces may not be worth
the paper on which they are written.
IMHO, we are in trouble in any case because X12 has yet to produce a
test harness (test data) against which we can establish clearly whether
or not a guideline is in compliance. But least X12 has produced as
William calls it, " ..this vaunted Technical Report.." which is a start
in the right direction. The other positive is at least one party is
taking the issue of X12 compliance to court. I anxiously await the
outcome - its implications for EDI and XML implementations may be far
reaching (XML does have the same issue with DTDs/schemas in a true
'standards' based implementation environment). This litigation is
"calling X12's bluff" if it is in fact a standards body or not.
Has anyone else been legally challenged in court for claiming to use
"X12 compliant" IGs? William, has Foresight been asked for comments in
the DoD's case? Does anyone have any knowledge as to X12's position on
its technical reports regarding this case?
Ken Steel - I agree with your initial response to the mud slinging, but
I think I've found a grain of merit to William and Jonathan's exchanges.
Jonathan - you still didn't answer William's question on the particulars
of HIPAA. If I were HIPAA, I'd want to know.
Harry Steck, Maj., USAF (Ret) - not on the front lines any more!
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