Douglas,

I recently participated in the development of Internet-based online systems with a major health plan.  It should be noted that there may be a qualification regarding the requirement to use standard transactions (such as 270/271, 278, etc.) with online systems, i.e. the format portion of the rules may not apply.  I refer to HHS HIPAA FAQs at http://aspe.hhs.gov/admnsimp/faqtx.htm#overInternet, which, in part states:

"Internet transactions are being treated the same as other electronic transactions. However, we recognize that there are certain transmission modes in which the format portion of the standard is inappropriate. In these cases, the transaction must conform to the data content portion of the standard."


During planning, we also concluded that the CE custodian of the data (in this case, the health plan) must offer an option for approved users to access the data in a manner that complies to the full requirements, including format specifications.  We accomplished that by offering a separate batch capability in addition to online services.

Regards,

Steve Moe
eBUSINESS AS USUAL, LLC
[EMAIL PROTECTED]

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