Although you wouldn't be out of compliance with the standard, the Imp Guides
are named in the Transaction Final Rule. So you would not be generating a
HIPAA-compliant transaction if you populated a "not used" field.
-----Original Message-----
From: Gibbs, Dale [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, September 25, 2001 7:18 AM
To: '[EMAIL PROTECTED]'
Subject: RE: 4010 Transaction vs. HIPAA Compliance
HIPAA Implementation Guide (IG) is not a standard. It is the instructions
for using a standard. In this case ASC X12. ASC X12 is the standard, so you
are not out of compliance with the standards unless you break ASC X12 design
rules. By using the 'not used' portion of the implementation guide, you may
be compliant with the standard, but not compliant with the implementation
guide. There is a difference.
Dale Gibbs
Chair, ASC X12J
Technical Assessment Subcommittee
(614) 793-7155
[EMAIL PROTECTED]
-----Original Message-----
From: Larry Watkins [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, September 25, 2001 8:29 AM
To: [EMAIL PROTECTED]
Subject: RE: 4010 Transaction vs. HIPAA Compliance
While I see Terry's point on the spirit of this, what he is describing is
more like the 'Optional' data usage that is widely used today. It goes
something like this:
Payer A receives claims from Provider X and Provider Y. Provider X sends
data that is marked 'not used'. Provider Y does not. For some reason,
Provider X gets paid more, or differently, or something. Provider Y asks
Payer A, "Why did you pay me differently than Provider X?" Payer A
responds, "Well, I received this data from Provider X that is marked 'not
used'. I don't require this data, but when I have it I adjudicate
differently. If you'd like, you can also send this data." In this
scenario, Provider Y will choose to also use the 'not used' element because
he understands that he must to get paid appropriately. Suddenly, Payer A
is, in a sense, requiring the 'not used' element in certain situations to
give providers what they want.
The end result of this is non-standard use of the standard. We're back to
needing to know the individual, proprietary rules of each payer in order to
handle transactions. It also raises some questions. When I send data that
is 'not used', will the 'traits' (i.e., definition, valid values, length,
etc.) be standard? Will we not just end up with different 'requirements'
for different trading partners?
What Payer A needs to do in the scenario above is find a way to get the
information using the standard implementation, or work to have a change made
to the standard. This concept of eliminating 'optional' as a data usage is
new to the industry. I understand how inflexible it seems, but I believe it
is the intent of HIPAA.
Hope this helps,
Larry
-----Original Message-----
From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED]]
Sent: Tuesday, September 25, 2001 7:43 AM
To: [EMAIL PROTECTED]
Subject: Re: 4010 Transaction vs. HIPAA Compliance
I disagree. I believe if the field is marked "Not Used" you are not
required to use it. I don't think that is grounds for rejection. If data is
sent that is the prerogative of the sender, not using the data is the
prerogative of the receiver.
The receiver does not have to use, edit or scan the field. To just reject
the claim would not be in the true spirit of HIPAA.
Thank you,
Terry Christensen
[ IS Administration Simplification EDI
Telelphone: (402)351-6370
Fax: (402)351-8025
e-mail: [EMAIL PROTECTED]
Jan Root
<janroot@uhin To: [EMAIL PROTECTED]
.com> cc:
Subject: Re: 4010 Transaction
vs. HIPAA
09/24/2001 Compliance
08:26 AM
Please
respond to
transactions
Chris
The short answer to your question is that if an element/segment/loop is
marked
"Not Used' then it is NOT USED. If a provider is sending you a HIPAA 4010
837
with marital status data then you can reject it as a non-HIPAA-compliant
transaction. This is sort of what having a national standard is all about:
everyone doing it the same way. This way you know what to spend your
limited
resources on: building a field for marital status on an incoming HIPAA 837
is a
waste of your resources.
Anyway, that's my non-official, non-legal opinion!
j
"Graff, Chris" wrote:
> Hello all. We are working on a HIPAA data store and claims processing
> application. There is a question that has been plaguing our minds here.
>
> If you look at the 4010X098 or 4010X096 manuals, there are many fields
that
> state "Not Used." Because these fields are not used, I was under the
> assumption that we should not store this data. For the majority of these
> fields, this is a no-brainer. Some of the NM1 loops specifically can
hold
> information that would never pertain to certain entities within the loop.
> For instance, there is no reason to keep track of NM111(Entity
Identifier's)
> for the submitter loop.
>
> Some pieces of data, however, seem to be elements that providers or
payers
> may be keeping track of at the moment. One in particular that we found
was
> the marital status element, which is on a normal UB-92(locator 16), but
is
> listed as not used in the 4010X096 manual. Once we found this difference
a
> number of different questions came up.
>
> 1. Do we accommodate for this field because it is on the form, and there
> might be a chance that this particular data element might be passed
through
> our processing system?
>
> 2. If we accommodate for this field, does that make us not HIPAA
compliant
> because we have claims running through the system that contain non-HIPAA
> compliant data?
>
> 3. Should we just accommodate all the possible fields that could appear
on
> a 4010 even though it states in the manuals that they are specifically
not
> used? Once again would we then be not compliant if we did?
>
> Any thoughts on these questions would be greatly appreciated.
>
> Thank you,
>
> Chris Graff
> United Wisconsin Proservices
> (414)226-6022
> 800-822-8050 x6022
> [EMAIL PROTECTED]
>
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