Anita,
As I read your message, I interpret your outside vendor to be a
business associate of yours and not a covered entity -- such as a
provider. Thus communication of claims information between your
outside vendor and you is not a covered transaction; i.e., this is not
a claims communication between a provider and a health plan. {See 45
CFR 162.1101 (a).} As a consequence ...
- Your outside vendor is not required to send you HIPAA compliant
formats, but may do so if you and they wish.
- Your outside vendor is not a HIPAA clearinghouse as they are not
translating non-standard electronic messages to standard electronic
messages nor vice-versa. Their sending (or non-sending) of HIPAA
compliant or non-compliant messages is not governed by HIPAA in
this regard either.
- This originally paper data is indeed not covered at all (from a
transaction code set / EDI perspective) because you are
using non-covered entity business associate resources to convert
this data from paper to an electronic format for auto-adjudication.
I hope this helps clarify your situation and reduces some stress on
this subject for EDI purposes.
Dave Feinberg
Rensis Corporation [A Consulting Company]
206-617-1717
[EMAIL PROTECTED]
----- Original Message -----
From: "Anita Mosley" <[EMAIL PROTECTED]>
To: <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]>
Sent: Tuesday, January 15, 2002 11:24 AM
Subject: Paper Claims into a Paper-less System
We currently out-source our mail handling to an outside vendor. One
of the things they do for us is to key paper claims that have been
mailed to us into our "translated EDI" format and send them to us for
processing. In this instance we have received paper claims from the
provider/subscriber and NOT EDI.
Questions have come up:
- Are they required to send us HIPAA compliant formats?
- Are they considered to be a "clearing house" so we can continue to
receive non-compliant translated data from them?
- Is this data not covered at all (from a transaction code set / EDI
perspective) because we have received paper claims and are using
external/internal resources to convert them to an electronic format
for auto-adjudication?
- Other options/opinions?
I think we understand how this practice is affected by the privacy and
security pieces.
Thank you.
[EMAIL PROTECTED]
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