As a follow up to the intermittent, but continuing, discussion of who is the
"real" sender and receiver for HIPAA interchanges I did a search on the
current HIPAA IG's to see what I could find. Interestingly, no where do the
HIPAA guides ever indicate that the sender is or could be a clearinghouse.
I think we need to clearly get this out on the table and reach consensus on
this issue as well before the water gets so muddied it can't be cleared.
Below are some excerpts from the various guides that illuminate this topic.
Rachel
Rachel Foerster
Rachel Foerster & Associates, Ltd.
Phone: 847-872-8070
Excerpt from Section 1.3.2 837P HIPAA IG
Batch - When transactions are used in batch mode, they are typically grouped
together
in large quantities and processed en-masse. In a batch mode, the sender
sends multiple transactions to the receiver, either directly or through a
switch
(clearinghouse), and does not remain connected while the receiver processes
the transactions. If there is an associated business response transaction
(such
as a 271 response to a 270 for eligibility), the receiver creates the
response transaction
for the sender off-line. The original sender typically reconnects at a later
time (the amount of time is determined by the original receiver or switch)
and
picks up the response transaction. Typically, the results of a transaction
that is
processed in a batch mode would be completed for the next business day if it
has been received by a predetermined cut off time.
and from the same IG on page 49
* NOTE
If no rule appears in the notes, the item should be sent if the data
is available to the sender.
and some more on page 573
BILLING PROVIDER/SENDER: Premier Billing Service,
and more from page 574
ELECTRONIC ROUTE: billing provider(sender) to Clearinghouse to XYW REPRICER
(receiver) to AHLIC (not shown);
Clearinghouse claim identification number = 17312345600006351.
>From the 820 IG
SITUATIONAL N102 93 Name X AN 1/60
Free-form name
HEALTH CARE INDUSTRY: Information Receiver Last or Organization Name
SYNTAX: R0203
1156 For HIPAA Health Premium Payments this element is REQUIRED.
1197 This is required when the sender needs to relay the receiver�s name.
SITUATIONAL PER03 365 Communication Number Qualifier X ID 2/2
Code identifying the type of communication number
SYNTAX: P0304
1131 This is required when the sender needs to relay communication
information.
>From the 835 IG
SITUATIONAL BPR07 507 (DFI) Identification Number X AN 3/12
Depository Financial Institution (DFI) identification number
INDUSTRY: Sender DFI Identifier
REQUIRED TRN02 127 Reference Identification M AN 1/30
Reference information as defined for a particular Transaction Set or as
specified by the Reference Identification Qualifier
INDUSTRY: Check or EFT Trace Number
SEMANTIC: TRN02 provides unique identification for the transaction.
1031 This number must be unique within the sender/receiver relationship.
The number is assigned by the sender.
For example, if a payment is made by check, this number should be the
check number.
