Hi Kepa and Chris,
We has the question of storing the information that we do NOT use to process/adjudicate a claim early on and found the following:
Per the HHS HIPAA website- FAQ Analysis as of 8/27/01 (Version 3.5) it states"...Data that a health plan receives, but doesn't use to process the claim, must be stored to be used later in building the outbound X12N 837 if they exchange coordination of benefits."
-----Original Message-----
From: Kepa Zubeldia [mailto:[EMAIL PROTECTED]]
Sent: Sunday, September 23, 2001 4:29 PM
To: [EMAIL PROTECTED]
Subject: Re: 4010 Transaction vs. HIPAA Compliance
Chris,
Great questions.
The HIPAA regulations govern the exchange of electronic data for certain
business functions. They do NOT govern what you do with the data one it
is in your hands. Except that you have to be able to exchange data with
other trading partners and therefore you may need to hold certain
received data for which you have no other use.
But your system can (will) certainly hold other data elements. For
example, because you will still receive paper claims with box 16 filled
in, or for other business reasons. For example, once the provider and
payer identifiers come out, some entities plan to map those to their own
internal identifier. Nothing wrong with that.
You may even hold less data than a HIPAA compliant claim, and still be
in compliance. For example, if you operate a business that only
adjudicates DME claims as an outsourcer for other payers, there is
probably no reason for you to store the spinal manipulation, ambulance,
anesthesia, or other special requirements of the claim, as you would
never see those. Still, that does not make you non-compliant.
The gap analysis phase is critical in this HIPAA compliance business,
and there is not one gap analysis that will fit everybody. You are on
the right track.
Kepa
"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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