Hi - just a couple of comments on p. 3.

1) Paragraph 1, sentence 2: "It is expected that testing with trading
partners will occur between April an October of 2003, as most of the
industry is expecte to file for the ASCA extenstion."  I strongly suggest
striking out this sentence, and modifying the one that follows.  Reasoning:
there is some trading partner testing - b to b - going on today.   There's
no reason for everyone to wait until 4/03 for b-to-b testing, even if they
HAVE filed for ASCA.  We don't HAVE to all be overwhelmed, I hope...

2) First paragraph, last line, I suggest replacing the line with "...HIPAA
and they have completed their own internal compliance test phase".
Similarly, second to last paragraph (penultimate paragraph - gotta show off
my knowledge of arcane words :^>) - first line of paragraph - I'd suggest
replacing "tested" with "internally tested".  But I'm not fully happy with
that phrasing either - the problem with the sentence is that third party
certification would be part of transaction compliance testing, not
subsequent to it.

3) Last three lines, same page - I suggest striking "Most trading partners
are not ready to produce outgoing transactions" - assuming that that's the
case now, by the time the paper is published that may have changed.  And in
some parts of the country, that is changing more rapidly than in others, but
that fact doesn't change the appropriateness of pre-b-to-b compliance
certification for the early adopters.

But most importantly, the argument for TCS compliance certification can
apply even after trading partners are producing outgoing transactions - when
we're past the initialTCS  implementation hump, covered entities and their
business associates will continue to enhance the systems that feed the EDI
transactions, and will enhance the ways that they use the transactions (e.g.
by adding previously-paper-filed PPO claims to their electronic filings).
Continuing with transactions compliance certification is probably not a bad
idea for the regression testing process...not as important as during the
initial HIPAA-fi-cation of things, but may still be handy...

Best wishes - Cynthia

Cynthia Korman, CHE, MS, MBA
Principal
Strategic System Solutions, LLC
973 394-9529
[EMAIL PROTECTED]
www.healthcare-systems.com



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