I don't think there is any doubt that the vendor would make himself a covered entity/CH if he was constructing the transactions and building the interchanges for his doctor-clients. But I don't really see this as any more onerous for the vendor... "In for a penny, in for a pound". If the vendor isn't building error-free interchanges based on the information streaming in from his doctors, then his doctors are still going to expect him to have written the software to accomplish this effectively "by remote control". If the doctors and staff members are the ones actually pushing the buttons and creating the messages, then are we going to be able to certify "Acme OD Manager" software as "tested and certified HIPAA compliant"... or will we have to certify each office using the software? I don't know why a software vendor would not want to offer a centrally managed [true CH] model to his doctor-customers. But to be fair and inkeeping with the letter of HIPAA, he needs to also provide a theoretical point-to point path for the doctor to the payor (and possibly back again).
Even if the doctors can get their own interchanges to the payors, the return paths will not be easy for payors to figure out... leaving them little other choice than the "mail drop-box on the payors server" option described by Peter as essentially unfair for the provider. When the process matures to the present level of email routing, we *may* see providers (and payors) unplugging from these CH-agents and going direct. But then "direct" is only an illusion and at the end of the day, I really think doctors would rather not worry about this crap... and get a monthly bill! (But then you do have nutty doctors doing their own electrical wiring... I'm one of them!) Regards, Chris At 02:04 PM 2/10/02 -0500, William J. Kammerer wrote: >If the small provider's software is capable of generating and receiving >HIPAA compliant transaction sets, then hopefully (based on what we do >here in the WEDi/SNIP ID & Routing group) address discovery will be >child's play! > >But I think if I were a software vendor, it probably would be easier to >distribute and maintain code which sent the required data to me, and >then I would package it up as a standard transaction - making me >something more than a mere software vendor. Would I then become a >clearinghouse now that I take (non-standard) data and convert it to >standard transactions? Would that now make me a covered entity? Or as >the doctor's out-sourced "IT department," can I call myself a mere >"business associate"? - this sounds like it has less onerous demands >than a "covered entity." > >There are various reasons the practice management software vendor would >want to centralize EDI handling in his own shop, including "locking" the >provider into his clearinghouse service. But, also, the vendor could >avoid either coding what in effect is an EDI translator, or licensing >pieces parts of a translator to include in each system he sells to >providers. The vendor then only needs one translator (though licensing >terms from the translator vendor are generally more onerous for a third >party service provider), and can more easily keep up to date with >changes to the standard HIPAA transactions - otherwise, he needs to keep >all the PM systems he sold maintained out in the field. > >The advantages of standard transactions still accrue to the provider, >though, even if the doctor's software is not directly handling them. >Costs should be lower, since at least the software vendor is on an even >playing field with all payers: the software vendor is not dependent on >other CHs since he can "talk" directly to the payers or their agents >using the standard transaction sets. > >The "(clever) doctor" still could do all this stuff himself, or use a >Practice Management system that handles all aspects of standard >transactions and address discovery (making the doctor completely >self-reliant). And he could also do his own plumbing and electrical >work. > >William J. Kammerer >Novannet, LLC. >+1 (614) 487-0320 > >----- Original Message ----- >From: "Christopher J. Feahr, OD" <[EMAIL PROTECTED]> >To: "William J. Kammerer" <[EMAIL PROTECTED]>; "WEDi/SNIP ID & >Routing" <[EMAIL PROTECTED]> >Cc: "Scott Bussinger" <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]> >Sent: Sunday, 10 February, 2002 01:02 PM >Subject: Re: Using a hybrid DNS > > >William, >I think most small providers (virtually 100% of them in vision) will be >lucky to have systems even capable of constructing an interchange >message, let alone one that passes all 6 or 7 levels of HIPAA testing. >I have no idea what the providers whose office systems can't get them at >least to an intact interchange message, are going to do... perhaps, sell >Tupperware. From that point, however, I believe the software vendor is >going to say, "Your new HIPAA-upgraded software will create standard >claims for you, but you still need to know where to send them. For only >$.50/claim, however, I will be glad to hard-wire all of your ISA sender >fields to point to me. When I get your interchanges, I'll take a peek >inside... first to count up the transactions to calculate your >transaction fee... then I'll look at each transaction and figure out the >correct/ultimate addressee. And [perhaps included in that same >$.50/claim fee] I'll make sure that all acknowledgements, error reports, >answering messages, and claim payments from the payors find their ways >back to you in the shortest possible time". > >This seems like the most logical approach for the PMS vendor because it >would take doctor-vendor communications out of the HIPAA-standard loop >and permit a richer, customized (XML, etc.) connection between the >doctor and what looks to him like the "big HIPAA insurance messaging >system in the sky". Entire "claim conversations" and "eligibility >conversations" can be assembled/tracked in the doctor's local system... >835s auto-posted, etc. The burden of address discovery remains with the >vendor, who is essentially functioning as the doctor's "IT department". > >As an alternative, however, doctors should be free to disable the >send-em-all-to-the-vendor feature... perform their own address >discovery... decide by themselves where each interchange should be >sent... and then populate each ISA accordingly. I can also visualize >third-party software similar to Seagate Crystal Decisions that a >(clever) doctor could use to build his interchange messages (probably >one interchange per payor) and maintain a local lookup table for the >best ISA address for each payor or "plan" that he sees... thus avoiding >the vendors' transactions fees by sending all messages directly to the >payor or the payor's designated CH-agent. > >-Chris Christopher J. Feahr, OD http://visiondatastandard.org [EMAIL PROTECTED] Cell/Pager: 707-529-2268
