STFCS was created by EHNAC (a non-profit organization) to assist the
healthcare industry's implementation of the HIPAA mandated EDI transactions
by providing an independent 3rd party transaction testing service based upon
the HIPAA implementation guides rather than the X12 standards. This
includes the EDI envelope, the structure of the transaction, and the data
elements including the all internal codes defined within the implementation
guides. The web site clearly states that it does not validate information
that is contained within free-form text within the implementation guides
(including interdependencies between segments) nor does it validate external
codes not contained within the implementation guide (which is planned for a
future version of STFCS).
All transactions contained in the library of compliant transactions are
compliant with X12 syntax as the HIPAA implementation guides do not violate
X12 syntax or design rules.
It is very unlikely there will ever be a testing or compliance tool that
will be able to validate 100% (HIPAA compliance) of the textual textual
notes contained within the HIPAA implementation guides that define these
interdependencies since they cannot be validated based upon the data
contained within the transactions themselves. For example in the 837 claim,
the destination payer loop contains the address which is situational and
only used when the transaction will be printed at some point between
submitter and receiver. Nothing within the transaction can be used to test
this to be true. Similarly some of the subscriber information is dependent
upon information contained on the healthcare ID card (when the subscriber
carries the card - different problem) such as group/policy number and plan
name. There are many such situations defined within the HIPAA
implementation guides.
What is important is that STFCS does provide X12 and HIPAA IG syntax
validation, tracks the success of the STFCS subscribers to assist mass
implementation, and provides a source of test transactions. EHNAC will
continue to evolve STFCS and enhance its capabilities into the future.
STFCS nor any other tool will be able to guarantee a transaction is 100%
HIPAA compliant. If they do... buyer beware.
Gary Beatty
EHNAC Commissioner
-----Original Message-----
From: Rachel Foerster [mailto:[EMAIL PROTECTED]]
Sent: Wednesday, February 14, 2001 2:55 PM
To: [EMAIL PROTECTED]
Subject: Re: HIPAA Compliant 837 4010
Jonathan, et al,
Subsequent to posting my message to the EHNAC site for HIPAA test
transactions I received the following message from Kepa. I was hoping to
hear from Lee Barrett before now to get some up-to-date information
about
when the EHNAC site would have HIPAA compliant test transactions
available.
Since I have not heard from Lee (it's now 1:50pm Wednesday, 2/14...Happy
Valentine's day to all!) I felt it important for interested parties to
have
Kepa's information. If and when I get current info from Lee I'll post it
as
well.
Please note that I'm not posting Kepa's message to in any way cast
stones at
EHNAC, but only to let interested parties know that at the present time
reliance on EHNAC for valid HIPAA test transactions is risky. I'm sure
that
EHNAC is working diligently to make sure that future test transactions
will
indeed be fully HIPAA compliant.
Rachel
> When I pointed you to the STFCS web site of EHNAC I was not aware of
the
> quality of their transactions.
>
> Now, after some detailed analysis of the transactions downloadable
from
> STFCS, I have determined that a substantial number of them are NOT
> compliant with HIPAA. There are some transactions with very basic X12
> syntax errors. Other transactions (most of them?) do not meet the
> implementation guide requirements.
>
> This comes from several problems with the STFCS system, the most
> essential one being the inability of STFCS to check relationships and
> dependencies across multiple segments. STFCS checks one segment at a
> time, and if all the segments, taken independently, pass the HIPAA
> requirements, the transaction is deemed compliant. This is not enough
> detail of testing to meet the HIPAA requirements. In fact, if you
have
> access to EDISIM with the HIPAA guidelines you can check this
yourself.
> Or you can take some of the STFCS transactions and run them against
the
> free FORESIGHT Previsto server yourself. The results will shock you.
>
> I have discussed this problem with Lee Barrett, executive director of
> EHNAC, and he has brought it to the attention of Washington
Publishing.
> WPC operates the STFCS web site. I would expect this situation to be
> corrected in the near future, as it is creating tremendous liability
for
> EHNAC by issuing certification of compliance to transactions that are
> clearly broken. I wish I could correct this situation immediately,
but
> I resigned from the EHNAC Commissioner position last summer, so the
best
> I can do is to bring this issue up to Lee Barrett for their action.
>
> As you may be aware, my new company, Claredi, is putting together a
> commercial HIPAA testing and compliance service, and we will be
> distributing sample transactions for people to test their translators.
> The first set of transactions (837s, 835) should be available on our
web
> site in March. Other transaction soon thereafter.
------------------------------------------------------------------------
----
---
Rachel Foerster pointed us at a source of HIPAA compliant transactions:
>
> Go to www.ehnac.org, follow the link on the left to the Standard
Transaction
> Format Compliance System, then follow the link on the left for the
Library
> of Compliant Transmissions.
Sadly, the first twenty of these are all unavailable, returning the
following
error:
HTTP 500.100 - Internal Server Error - ASP error
aspSmartUpload(0x800A0035)
File not found
/Library_download.asp, line 33
It seems a shame to have such a broken web-site ... I gave up after
twenty
web-server failures.
Are these not available simply as one ZIP file, so save having to click
on each one separately ?
Jonathan
------------------------------------------------------------------------
----
--
Jonathan Allen | [EMAIL PROTECTED] | Voice:
01404-823670
Barum Computer Consultants | | Fax:
01404-823671
------------------------------------------------------------------------
----
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