Sanjeev,

You wrote:
>I did not use the word "XML" since it raises hackles in the traditional X
12 / EDI Camp and in one of the discussion forums I have been beaten black
and blue.

Zapthink had beaten EDI black and blue in one of their research articles,
while comparing it with XML for B2B. After I sent them my responses to their
EDI beating, their article at
http://www.zapthink.com/reports/proscons-view.html looks very different and
it makes the reading very interesting when along read with the response. If
anyone wants my response document then please send me an email with subject
"zapthink" (to ensure that I apply rule to my inbox and do not miss sending
the document to you).

I don't agree to everything "glorified" they say about XML but I am
definitely not an XML beater either.  I have my own ideas where XML is more
useful, a hot topic, which is better suited for discussion over beer than
e-medium.

Cheers,

Ajay

Ajay K Sanghi
Managing Director

ABO Software Private Limited
B102 Gulmohar Park, New Delhi 110049
Tel: +91 11 6968976, 6512822 Fax: 6518873
Website: http://www.abosoftware.com
email: [EMAIL PROTECTED]


-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]]On Behalf Of
Sanjeev N Kulkarni
Sent: Thursday, April 25, 2002 12:45 PM
To: [EMAIL PROTECTED]
Subject: Re: Fw: HIPAA Compliance Tests





Martin and Marsha
Interesting! May I add my bit to a debate that is becoming stormy, high with
emotions but bascially a genuine emotion of anguish. The comments below are
in my individual capacity and do not reflect the view of my organization.
1. Free Stuff: Well we have to be fair to all the people who have put in
volunteer work. All free stuff is what it is . It is available on "as is
where is" conditions and it does give you a higher platform to take off
from.
Thank you all those wonderful people who have put in their time and effort.
We also looked at the 837 Transactions on the  Claredi Website and
discovered that the "free" test files are indeed incomplete and at times
incorrect.
( We are "one of the vendors who see this as a prime opportunity to
perpetuate their revenue" but by not spreading FUDD ---but that is another
story ! Also we wish Claredi the very best so they make their money and I
guess we should not grudge them since thay have been on it for a long time
!!).
I want to share the approach taken by us with a hope that it sheds more
light on the issue.
3. Fundamental Issues - How to tame the X 12 EDI beast ?
a) The more fundamental issue is that the transaction standards evolved out
of EDI a twenty-year-old technology.
HIPAA ASC X12N transactions are basically a new band aid paint job. Pressed
by mandates HIPAA initiative advocates fast-forward with a creaking EDI
technology and mind set. This forces implicitly antiquated thinking and old
methodologies to solve the HIPAA problem.
b) What we have done is that we have "objectized" the the transaction
entities into Elements, Segments, Loops ( and Regions which is our
abstraction ). We were delighted to find out that there was indeed a method
in the X 12 madness and our generic "object definitions" remained valid for
all the X 12 N HIPAA transaction standards like 837, 835,275 et al. I am
sure there are other folks who may have done this. So far not much to write
home about except that it does make job of checking SNIP/WEDI Level 2
Compliance every easy and "almost" automatic.
 Of course the wish is life would have been easier if the pdf standards were
available in machine readable format which we could then simply plug in to
the Level 1 & 2 SNIP/WEDI rule checker.

c) We also spent considerable time, effort, technology creation (and
money)in modeling the business rules embodied in these standards. We again
found out to our pleasant surprise that we could capture the rules of 837
Professional standard for example into set of 20 generic rules. These 20
rules are coded in appropriate machine readable format so that we can use
the rules to validate upto Level 4 automatically and create events for
checking Level 5, 6 and any other business rules.
The "machine readable" format that we use is XML. I did not use the word
"XML" since it raises hackles in the traditional X 12 / EDI Camp and in one
of the discussion forums I have been beaten black and blue.
We have found XML to be a convenient alphabet for modelling and but I could
not care less. It could be in a spread sheet format or whatever.

d) Once we were able to model the X 12 Transaction Sets formally, it comes
along with lots of freebies. For example element syntax checking can be
"formally" demonstrated to be correct. Similarly the Level 4 rules can be
demonstrated to be correct. However life has not been so simple. For example
some of the rules seem to be "ambiguously"  stated or it could be lack of
our domain knowledge as applied to Health Care and Insurance.
e)You will also notice that some organizations take efforts to come out with
their "versions" or data dictionaries of the the transactions which try to
limit or define a sub set of the transactions. I am not sure whether this is
right approach legally since HIPAA mandates that all Transactions have to be
accepted if they are in the HIPAA format.
Moreover  these data dictionaries again suffer from the same mind set -
words, words and words which obfuscate the matter further.
f)Our modelling approach outlined above does make the X12 (EDI) standard
intutive and simple. The approach is similar to having a higher level
language to mask the non intutive but powerful assembly language ( X 12 ).
The troops in our ranch feel that the beast has been tamed. Bottom line -
new folks can be inducted into the team without first requiring a Ph D. in
EDI and X 12.
4. Routing Issues:
Enough is being said on this but I get an uneasy feeling that it is going to
go the way of ISO 7 Level Communications model. It never took off. The more
simple TCP/IP, Internet protocols took off because they were not essentially
commitee driven.
Why should the mode of communications ( SMTP/FTP/VAN/HTTP or messaging like
IBM MQ, Microsoft MSMQ or JMS) be linked to the address of the entities ?
Why in the heavens is E mail addressing reliable? Use E mail as URL's  and
whether it gets communicated via FTP SMTP or whatever should be left to the
entities. Looks heretic but doable (after drilling down into this idea). The
email address need not have a person but could have an automatic process. Of
course these are my views and I leave it to the "learned"  commitee to
decide.
Encryption - Give me a break. No one is going to spend $$$'s to break into a
PHI of an individual. So for example go for 128 bit Encryption for PHI and
let keys be exchanged as part of TPA and be done with it.
Let the information go over dial up, Internet or whatever. For other
critical system information there is enough technology out there to take
care of security.

5. Certification :
Totally concur with Martin. This is no mans land and free for all wild west
scenario. We have written our parsers and validators and now we are having
the ignominy of getting them validated from one of my  competitors or start
test my product the hard way.
I have reasons to believe that all vendors mean different things when they
say that their products are "compliant" and they are not incorrect. Their is
no "standard transaction test suite"  which if you run will validate your
software or a vendor product. The SNIP/WEDI document on various levels is
absolutely insufficient, non-formal and does require leap of faith.
6. Last Word:
New technology can be applied to the X 12/EDI HIPAA problem if all of us
look at problem from new technology mind set. ( I know I am going to be
mauled for this statement -but so be it !).
Having said this and having spent my life in developing computing based
systems I have learned the painful way that even very small systems have to
be tested tested tested and tested. It does seem a leap of faith that when
there is no agreement on what constitutes a  stanard test suit how can there
be an agreement on what contitues a HIPAA Compliant Transaction. I remember
way back we use to vaildate Pascal Compiler against a test suit from some
Australian University ( not free I guess !).  But it was easy. Pascal was
formally defined so validation could be demonstrated by formal techniques
too.
Worst still there is no "formal public domain" language to model the
transactions. And for valid reasons how would organisations which have spent
time and money ( like mine and I am sure there are others) share this
knowledge free of cost?
Yes all HIPAA folks are working very hard ; so let us hope we are going
somewhere and not merely running on a tread mill and die of exhaustion.

Sanjeev N. Kulkarni
Chief Technical Officer
Advent Software Ltd.
+91-20-6119162
  Martin Scholl <[EMAIL PROTECTED]> wrote:

----- Original Message -----
From: "Martin Scholl"
To:
Sent: Tuesday, April 23, 2002 10:59 PM
Subject: Re: HIPAA Compliance Tests


> Excuse me, Marsha!
> I just went in selfdoubt to the Claredi website--> Free stuff
> There were 50 837's under WEDI SNIP defined testfiles. They all have an
> error condition listed. Broken 837's in my lingo
> Under business scenarios where another 30 or so testfiles. Maybe I am
struck
> with blindness, but there are no 4,700 scenarios. There are another 100 +-
> transaction pending but no data available.
> Let me get on my soapbox too.
> I don't want to belittle anybody's effort or hurt their feelings for all
the
> volunteer work that they are doing. I am a member of MAHI, the
Mid-Atlantic
> Hipaa Initiative, the local WEDI-SNIP initiative. I know about volunteer
> efforts.
> But let's be for real here. In 1 1/2 years we want to move 14 % of GDP,
> Gross domestic product of the US of A, from various file formats and
paper
> to EDI. 9 Protocols for sure, more in the making. This is EDI, the most
> non-intuitive data format on earth. The average implementation for
Wal-Mart
> business partners takes 9 months before things work smoothly. The
> healthcare industry as a whole is supposed to make it in 18 months now.
> There are only very few testfiles out. Only of one transaction set. The
> routing group does not know at this point which information goes into the
> ISA header, to make sure routing will work. There is no national
repository
> for routing information. Is it Dial-up, ftp, VAN or what? Encryption with
> VAN, not with Dail-up. What encryption, PGP?? The transaction group is
now
> talking ebXML and CPP's while 9 out of 10 hospitals haven't even evaluated
> how they will handle HIPAA. Most providers have no idea about HIPAA. They
> trust their vendors. Some vendors have no clue, groping for knowledge in
> the same conferences that I go to, participating in the same email groups
> that I am in. HIPAA certification is a vague concept. Claredi is praying
to
> be the chosen one.
> Other vendors see this as a prime opportunity to perpetuate their revenue
> stream by spreading FUDD, fear, uncertainty and disinformation, to get
their
> customers hooked on a proprietary solution with a per transaction fee.
> HIPAA transaction sets, aka administrative simplification, are hard work.
> They take time to understand, more time to implement and even more to
test.
> Just having 50 broken 837's and 30 good ones is not going to make this
> transition work.
> It might very well be that there are forces in the government who have no
> interest in the success of HIPAA transaction sets. Who wish they would go
> the way of the metrification. You remember: In the 1970's this country by
> act of Congress went from the imperial system to the metric system. The
> last time I checked, the US and Burma alone in this world still measure
> distances in feet, weight in ounces, temperature in Fahrenheit. Don't be
> assured that a similar fate is not in store for the Clinton Healthcare
> reform. We all might be working our behinds off to get things ready, while
> Congress decides to grant one delay after the other until the issue goes
> away.
> I am not shy to do the heavy lifting, read the IG's , write parsers, test,
> tie in business rules and so on. But for an effort of this magnitude, I
> believe the equipment supplied so far, in the form of a few testfiles of
one
> out of 9 protocols make this a leap of faith.
> So, now I feel I can climb down from my soap box.
> Feel free to join in this discussion but please, lets not get into
personal
> attacks. We are all working hard.
>
> Martin Scholl
> Scholl Consulting Group, Inc.
> 301-924-5537 Tel
> 301-570-0139 Fax
> [EMAIL PROTECTED]
> www.SchollConsulting.com
>




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