I think this is a particularly significant point. There are some implications to all this (these are not absolute and I'll include my own rebuttals further down the line):
1. Unlike other EDI activities, this one is federally mandated and, as best I've been able to gather, the IGs carry the weight of law (though no doubt the lawyers and the courts will be the ones to ultimately determine how heavy they'll weigh--I'm guessing gov't lawyers will push to make them "heavier" while corporation lawyers will push to make them "lighter"). 2. Therefore, one might say (if one were an optimist--and who is these days in EDI? 8-) ) that the IGs must be consistently used across all players (that is to say, if you use it, you use it in exactly the same way as everyone else who's affected by HIPAA). 3. Therefore, if everyone's doing the same things with all the IGs, there's no real need for trading partner agreements or at least little more than a letter of introduction. That's pretty dang close to Open-EDI. And that "letter of introduction" could be stored in the CPP registry and contain two basic facts: a) the identifier(s) the party will be using to identify itself to other HIPAA compliant folk, and b) the list of IGs that they support. Having said that, I'd also make the following observation (my "rebuttal" as it were): I betcha betcha betcha that despite 3000+ pages of federal law IGs, people are going to get different answers as they implement the transaction sets amongst themselves and that there's gonna be lots of negotiation between covered entities, business associates, etc. over what's what and where it's at. *sigh* This is further complicated by the things that would be nice to have but aren't covered in the HIPAA final rules, such as 997s, 824s, etc. Best regards to all, Bill Chessman Peregrine Systems, Inc. (though the opinions are mine and not necessarily shared by the company) -----Original Message----- From: William J. Kammerer [mailto:[EMAIL PROTECTED]] Sent: Tuesday, May 28, 2002 4:02 PM To: WEDi/SNIP ID & Routing Subject: Re: TA1 responding to non-participating health care providers Martin: I don't think you misunderstood what I was saying at all: I think open portals - and all the stuff you talk about - are indeed mandated by HIPAA; how else would it be non-discriminatory? This issue may not be settled soon - but it has to be discussed. It's funny that most of the discussion on lists like HIPAAlive centers around marginal issues, like "If I'm a self-insured employer and my brother-in-law is a jackass, do I have to use an 834 to enroll employees with the plan?" - which couldn't possibly have any effect on administrative simplification since you're only talking with one plan; who give's a whit whether you use a spreadsheet or the standard 834? The real radical notion is this Open-EDI I'm talking about - though it seems few payers are thinking along these lines. Remember: "A health plan may not refuse to process a transaction simply because it is a standard transaction." I can't but think if a payer would have taken a paper claim (from a par *or* non-par provider), they absolutely must take the HIPAA standard transaction, the absence of a trading partner agreement or "certification" notwithstanding. We do hope that no mis-routing of claims will happen - that's where the Healthcare CPP Registry will help: if you have the plan's identifier, you'll get the correct CPP, which points to the plan's open portal. William J. Kammerer Novannet, LLC. Columbus, US-OH 43221-3859 +1 (614) 487-0320 ----- Original Message ----- From: <[EMAIL PROTECTED]> To: <[EMAIL PROTECTED]> Sent: Tuesday, 28 May, 2002 06:23 PM Subject: RE: TA1 responding to non-participating health care providers Whoa!, Bill... You make it sound as if payers will be obligated to open their gateways, carte blanch, to any who wish to direct a file our way. While there may, in the past, for some payers, have been requirements that a provider must be "participating" in order to submit their claims electronically or otherwise capitalize on their EDI investment(s), that in no way means that we have to take in a file from entities we haven't entered into a Trading Partner Agreement with and set up in our system(s)(participating or not). If a provider were to unilaterally determine how to route data to us and get it wrong, it would increase the chance that we might be receiving another carriers information in error. There is also the issue of our not being able to process their information or inquiry as certain basic identifiers (part of the TPA) were not used or used correctly. I know it flies in the face of admin simp., but, until all the identifiers are finalized, we will have TPA's that look a lot like what we have today. If I have missed something in this thread or misinterpreted your intent, please accept my apologies in advance. _____ Martin A. Morrison Project Management Consultant HIPAA Implementation/Coordination Blue Shield of California 4203 Town Center Bl., Ste. D1 El Dorado Hills, Ca 95762 Ph: (916) 350-8808 Fx: (916) 350-8623 This electronic message is intended only for the individual or entity to which it is addressed and may contain information that is confidential and protected by law. If you are not the intended recipient of this e-mail, you are cautioned that use of its contents in any way is prohibited and may be unlawful. If you have received this communication in error, please notify the sender immediately by e-mail or telephone and return the original message by e-mail to the sender or to [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]> . We will reimburse you for any cost you incur in notifying us of the errant e-mail. Thank you. -----Original Message----- From: William J. Kammerer [mailto:[EMAIL PROTECTED]] Sent: Tuesday, May 28, 2002 2:59 PM To: WEDi/SNIP ID & Routing Subject: TA1 responding to non-participating health care providers Just one more reminder - this time from the EDI-L mailing list - that we have to keep in the back of our mind something almost no other industry has wrestled with in EDI before: Unsolicited Transactions, � la Open-EDI, from non-participating providers. Payers will have to be prepared for taking in anything coming along from providers - if they would have taken paper before, they can't put roadblocks up discriminating against the equivalent Federally mandated HIPAA standard transactions! Not only will they have to make available an open portal for receiving electronic claims and eligibility inquiries (advertised in our Healthcare CPP Registry), but they will have to make sure their translators can accommodate ISA senders they've never seen before. William J. Kammerer Novannet, LLC. Columbus, US-OH 43221-3859 +1 (614) 487-0320 ----- Original Message ----- From: "Rachel Foerster" <[EMAIL PROTECTED]> To: <[EMAIL PROTECTED]> Sent: Tuesday, 28 May, 2002 01:32 PM Subject: RE: [EDI-L] TA1 On the other hand, the TA1 may become a useful/important ack in health care under HIPAA since it's entirely possible that a payer/health plan/insurance company could receive an unsolicited interchange containing health care claim transactions from non-participating health care providers. In this scenario, the translator won't know about the sender in advance, but the receiver needs to know it's received an interchange from an unknown sender and then take appropriate action. Rachel Foerster Principal Rachel Foerster & Associates, Ltd. Professionals in EDI & Electronic Commerce 39432 North Avenue Beach Park, IL 60099 Phone: 847-872-8070 Fax: 847-872-6860 http://www.rfa-edi.com -----Original Message----- From: DPR [mailto:[EMAIL PROTECTED]] Sent: Sunday, May 26, 2002 11:19 AM To: [EMAIL PROTECTED] Subject: [EDI-L] TA1 In my experience, I have never found anyone who wanted or cared about a TA1 segment. About all it says is roll call "I'm here'. There are quite a number of translators who don't even know what a TA1 is and choke if one gets through. So save your time and money and forget about the TA1. If the ISA/IEA is bad, you will never get a 997 in return. Dennis Robinson
