William, I hate to burden you with having to respond to such frivolous discussion, but I am still a little confused of where this open portal exists that you contend is so obviously imbedded in HIPAA?
E-mail (you make a great point of how poorly secured it is today) can still be managed to handle unknown or unwanted entities. That is a result of 95+% of the healthcare world being on Exchange or Lotus Notes. Products that manage the delivery, receipt and security for fairly unsophisticated users. Is there such an animal in your open portal module? An if so, do you really believe that there is a possibility of having it universally accepted in Healthcare in the 15-16 months that covered entities have to reach compliance? What is the platform of the open portal? I know a great deal of the payers that I work with intend to stay with a BBS dial up, they just don't have the time or sophistication to implement otherwise. What about Medicare? Last I heard, they refuse to use an open network. (Anyone listening from Medicare, I would definitely love to hear a reaction to the concept that you will have to accept claim openly). As it stands today, Medicare is one of the biggest sticklers for pre-registration, and I guarantee this is a piece of their fraud prevention/detection policy. Maybe all Payers should just implement an IVANS network solution? (Send my commission to the below address) I have heard numerous responses to the e-mail exchange we have going here that this should be the future goal, and maybe it should, but realistically it will not happen with the timeframes left. I also have issue with the use of "intent of the law". For any of us that deal with contracting we know intent and what is worded in the contract are two different things, and good luck getting the intent by in court. Finally, the little exercise here with the e-mail is the perfect argument for not having an open portal: "But it did require me to read at least one paragraph of the missive." Does this not fly totally in the face of "Administrative Simplification" ? I have to staff an EDI area to open receipts and review them? Or I could spend $$$$ on trying to develop logic to deal with this. Diminishing returns is the key phrase for the day. It is ridiculous to expect a payer to spend the type of resources they would have to so Dr. Bob can send his single claim from Timbuktu, never to be heard from again. And before we get started on "Aww the poor payer" track, keep in mind that delays caused to the payer will result in diminished AR flow to the Provider. What is good for the Goose is Good for the Gander! We need to keep our eyes on the prize of finding real savings and worry about the 80/20 that can provide a real impact. Open portals are not, and cannot be mandated next October. Greg Koller Manager of Operations and Business Development United Wisconsin Proservices (414)226-5520 [EMAIL PROTECTED] Be sure to visit our website at http://www.uwproservices.com/ -----Original Message----- From: William J. Kammerer [mailto:[EMAIL PROTECTED]] Sent: Friday, May 31, 2002 7:39 AM To: WEDi/SNIP ID & Routing Subject: Re: Open Portals and "Blind Trust" I guess you could say my e-mail server is an "open portal." You never know what's going to come across; see below. Now even without examining the headers (which probably aren't forged, otherwise the spaminator would've discarded the message), I can tell I needn't bother with this e-mail. But it did require me to read at least one paragraph of the missive. This is analogous to a payer simply reading the (purported) EDI file coming in on the open portal: if it doesn't have the correct HTTP or MIME headers, for example, somebody's completely wasting your time, and it can be discarded or rejected with an HTTP response code or bounce e-mail. Same thing if you can't decrypt the S/MIME with your private key or make out an ISA in the body or an attachment. Once you do get the start of an interchange, if the remainder doesn't conform to X12 syntax, a negative TA1 or 997 can be returned. If it looks like good EDI, but doesn't comply with the HIPAA IG, an 824 can be returned. Of course, maybe I have the order things are done all wrong here, and it's certainly more complicated than this depending on the protocol and packaging, but you get the drift. Keep in mind that IETF EDIINT AS1 and AS2 implemented by many commercial software packages takes care of a lot of these details in a well-defined sequence. But suffice it to say, for those payers worried about viruses and fraud, it's clear a scofflaw isn't going to get too far if he can't fake a good transaction with the proper transport and packaging. And if he can fake a seemingly valid 837 using the proper segments, situational elements, codes, dates and IDs, hire him, 'cause a lot of smart folks are hung up over these very issues all over the country. Assume a correctly formatted 837 got past this gauntlet, and it's from an "unknown" provider. For those payers still suspicious of the EDI and any "cooties" contained within, I suppose there's always the option of taking the 837 and printing it out on a HCFA 1500 or UB92 claim form, pretending as if it came in the mail or on the fax! At that point, the payer is home free: there's now no danger of "disadvantaging" standard transactions vis-�-vis paper! Somebody could even make a cottage industry doing exactly this: taking in standard transactions and dropping them to paper. Actually, come to think of it, clearinghouses do this all the time! So a payer, in this case, would have his "open portal" maintained at the clearinghouse - a free conduit unburdened by logons, passwords, fees and subscriptions. The payer's CPP Electronic Partner Profile Delivery Channel ("EDI Address") would simply point to the clearinghouse. Standard transactions coming from "known" partners would be passed through to the payer as EDI, and "unknown" providers would have their stuff dumped to paper. If somehow that makes the payer happy (though Lord knows why), that's perfectly compliant with the law which says nothing about "disadvantaging" unknown or non-par providers vis-�-vis participating providers. I think we've beaten this dead horse long enough. Payers must maintain open portals for accepting standard transactions. The HIPAA TCS Rule requires payers to take in standard transactions on a non-discriminatory basis: no "vetting," no "certification," no "enrollment," no nothing, period. William J. Kammerer Novannet, LLC. Columbus, US-OH 43221-3859 +1 (614) 487-0320 ----- Original Message ----- From: "Dr. Mrs. Mariam Abacha" <[EMAIL PROTECTED]> To: <[EMAIL PROTECTED]> Sent: Thursday, 30 May, 2002 08:26 PM Subject: HELLO Alternate e-mail: [EMAIL PROTECTED] I am Dr. Mrs. Mariam Abacha, wife to the late Nigerian Head of state, General Sani Abacha who died on the 8th of June 1998 while still on active service for our Country. I am contacting you with the hope that you will be of great assistance to me, I currently have within my reach the sum of $18.92 million U.S dollars cash which l intend to use for investment purposes outside Nigeria. This money came as a result of a pay back contract deal between my husband and a Russian firm in our country s multi-billion dollar Ajaokuta steel plant. The Russian partners returned my husband s share being the above sum after his death. Presently, the new civilian Government has intensified their probe into my husband s financial resources, which has led to the freezing of all our accounts, local and foreign, the revoking of all our business licenses and the arrest of my First son. In view of this I acted very fast to withdraw this money from one of our finance houses before it was closed down. I have deposited the money in a security company with the help of very loyal officials of my late husband. No record is known about this fund by the government because there is no documentation showing that we received such funds. Due to the current situation in the country and government attitude to my family, I cannot make use of this money within, thus I seek your help in transferring this funds out of the sub African region. Upon your consent contact me via e-mail immediately for further discussion and clarification. Bearing in mind that you may assist me, l has decided to part with 20% of the total sum. Your URGENT response is needed. Please include your personal phone and fax number. Please if interested contact me using only [EMAIL PROTECTED] Regards Dr. Mrs. Mariam Abacha
