Wes,

I wouldn't at all be surprised to learn that the actual situation of how CMS
really handles communications is much different than its public policy
statements ... and along the lines you outline below.

Unfortunately, I don't see anything in the HIPAA final or proposed regs that
requires the use of the Internet or any other transport method....only that
if the Internet is used, encryption is required.

So....I guest that the bottom line is that CMS can choose to go a different
direction and not use the Internet, even though it has an Internet policy
that would seem to allow it???

Strange world we live in...but this is our government in action.

Rachel

-----Original Message-----
From: Rishel,Wes [mailto:[EMAIL PROTECTED]]
Sent: Friday, May 03, 2002 3:04 PM
To: 'WEDi/SNIP ID & Routing'
Subject: RE: Medicare says 'no' to using the open internet


Rachel, you probably know more about this than I, but here is what I have
heard:

a) the policy exists you cite exist, but

b) program directives from CMS tell Medicare contractors to follow a
different approach ...

c) contractors except transactions over a CMS-built private IP-network that
providers connect to by dialing into a modem bank which uses PPP.

Going beyond what I have heard into speculation: Thus providers get to
(maybe are required to) use IP-based protocols, but various security
concerns are alleviated because the CMS IP network is not actually
interconnected with the Internet. Among the requirements that would be
removed would be the HIPAA requirement for encryption.

(Hopefully, this note will be close or will stimulate someone telling us
what the real situation is.)

-----Original Message-----
From: Rachel Foerster [mailto:[EMAIL PROTECTED]]
Sent: Friday, May 03, 2002 12:34 PM
To: 'WEDi/SNIP ID & Routing'
Subject: RE: Medicare says 'no' to using the open internet


Wes, et al,

I would agree that the need to be able to specify a variety of transport
methods and protocols goes beyond just what CMS requires....but it's
incorrect to presume that CMS prohibits the use of the Internet. See my
other post with CMS' current Internet policies.

Rachel

-----Original Message-----
From: Rishel,Wes [mailto:[EMAIL PROTECTED]]
Sent: Friday, May 03, 2002 2:18 PM
To: WEDi/SNIP ID & Routing
Subject: RE: Medicare says 'no' to using the open internet


Since many payers will follow the CMS lead, the need is broader than only
for Medicare.

-----Original Message-----
From: William J. Kammerer [mailto:[EMAIL PROTECTED]]
Sent: Friday, May 03, 2002 11:39 AM
To: WEDi/SNIP ID & Routing
Subject: Medicare says 'no' to using the open internet


I came across Christine Stahlecker's presentation entitled
"Telecommunication and HIPAA: Issues, Concerns, Recommendations," given
at the HIPAA SUMMIT WEST II on March 13 in San Francisco, at
http://www.ehcca.com/presentations/HIPAAWest2/stahlecker.ppt.  In there,
she gives some "buzz" to our modest little work effort. Clearly, Chris
shares our vision of Open-EDI and frictionless trading using the
Internet, while still accommodating the important role of Clearinghouses
in supporting providers and payers.

Unfortunately, from what I can gather from one of Chris' bullets, a fly
in the ointment is Medicare's (CMS) refusal to entertain use of the
Internet for the exchange of standard EDI transactions because of real
or perceived security concerns.  Unless and until CMS changes its mind
and authorizes the use of the Internet to exchange HIPAA transactions
with Medicare contractors, we might have to provide some capability in
our Delivery Channel ("EDI Address") to accommodate dial-up or leased
line protocols -  regardless of what I said in "Should we even waste
time defining Delivery Channels (EDI Addresses) to accommodate non-IP
protocols?" last Tuesday.

Does anyone have any inside insight on CMS' resistance to using the
Internet for the exchange of standard transactions?

William J. Kammerer
Novannet, LLC.
+1 (614) 487-0320


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