With the advent of standard transactions, the marginal cost to large
providers (or their billing service or clearinghouse agent) of using
EDI with any "new" payer that comes along (i.e, their first encounter
with a patient insured by that payer) will drop significantly.
Regardless of the payer, the provider can now be reasonably sure the
payer should "understand" any standard HIPAA transaction thrown at it,
say an 837. Would it be possible that the cost of mapping to any
particular payer's EDI guidelines was the real barrier to providers
(institutional, at least) doing electronic billing on behalf of their
patients in the past?

But now individual EDI guidelines dictated by the payer are a thing of
the past.  As an aside, I do suspect that some payers will try to use
"companion" guides in much the same way, thinking they're just renamed
implementation guides.  Except now, they will find that most of the
(arbitrary) restrictions they place in these "companion" guides are
unenforceable:  I've even seen these guides say what particular X12
delimiters to use!  A payer (or provider, or clearinghouse for that
matter) must take a standard transaction as long as it conforms to the
HIPAA IG:  if the sender's delimiters are acceptable by the X12
application syntax rules and the HIPAA IG, the recipient should be the
one doing the adapting.

So now the only thing standing in the way of providers sending standard
transactions to any old payer is the ugly, old, manual and onerous EDI
enrollment process.  As some of our correspondents have told us in the
past, this is one area where clearinghouses have an advantage (over
point to point). Generally, when a provider is signed up with a
clearinghouse, she can send electronic transactions to any payer
advertised by that clearinghouse, with the few exceptions of Medicare
and some commercial payers.  Kepa's and Marcallee's Clearinghouse
Power-of-Attorney concept was meant to break down that remaining
barrier.  Presumably, most payers "trust" any provider to send
electronic transactions to them via the clearinghouse for some reason:
maybe they think the CH will scrape the viruses and cooties off the
claims;  who knows?  Or perhaps the payers know that the CH will do some
kind of front-end edits to make sure the claims are reasonably coherent.

Certainly hospitals do courtesy billing with insurance companies they do
not "participate" with;  their ability to do eligibility inquiries,
claims and COB electronically (as opposed to telephone calls, faxes and
paper) should increase their operating efficiency.  Unlike a physician
provider, hospitals can't generally rely on the patient to pony up the
cost of a heart transplant ahead of time;  if they want the "business,"
they have to help the patient navigate the insurance waters - even
though the patient is ultimately "responsible" in a meta-physical sense.

But the issue of identification and routing of transactions to payers
from non-participating or out-of-network providers isn't one that
requires too much more analysis and discussion.  I suspect that it will
eventually fall out of the bigger "trust" problem that comes along with
the Healthcare CPP Registry.  If payers know they can "trust" a
provider - coming in out of the blue -  they're more likely to commence
electronic "trading" with them.  And that trust might be conferred by
digital IDs and signatures that, in effect, says the AMA "knows" the
provider, or the ADA "knows" the dentist, or some accreditation body
"knows" the hospital.  Or even that any other "known" commercial
insurance company "knows" the provider, thus building on a "Web" of
trust concept.

William J. Kammerer
Novannet, LLC.
Columbus, US-OH 43221-3859
+1 (614) 487-0320



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