Deborah, 
I agree with you.  We all have been working very hard around the clock to
comply with HIPAA requirements...
To point out your point then, would covered entities have an adequate plan
with available budget and resources to achieve the compliance on time after
they fill out the 10 minutes form? If planning where that easy...oh...boy...
Isn't the purpose of submitting a plan so that entities start thinking and
doing what need to be done accordingly? 

Once again, I agree that it should be more detail to answer the "why" and
enough prove to support it.

Fify Taslim, MD, MBA
C1st MIS Department
Ph. (626) 299-4299 ex.339
Fx. (626) 458-0415


> -----Original Message-----
> From: [EMAIL PROTECTED] [SMTP:[EMAIL PROTECTED]]
> Sent: Tuesday, January 15, 2002 11:13 AM
> To:   [EMAIL PROTECTED]
> Cc:   [EMAIL PROTECTED]; David Blasi; [EMAIL PROTECTED]
> Subject:      RE: Transaction Delay Question
> 
> 
> While I certainly support the goal of simplicity, I hope that in its
> interest the work group does not create a form which allows an entity to
> avoid completing the assessment work of why they will not be in compliance
> and how they plan to attain compliance.  This is one the key reasons some
> entities will not be ready -  they have not had a adequate plan, budget,
> or
> resources for readiness in comparison to their peers in the industry.
> 
> The form needs to be detailed enough to provide the NCVHS with summary
> data
> of the "why" and should require the entity to provide enough detail that
> it
> is evident they have created a reasonable plan of compliance.
> 
> I am a realist - I know there will be no army of reviewers available to
> review the plans - but it should be more than a paperwork exercise.
> 
> 
> Deborah A. Lelinski
> IDX/LastWord HIPAA Program Manager
> 206.689.0967
> [EMAIL PROTECTED]
> www.idx.com
> 
> 
>  
> 
>                     "Price,
> 
>                     Carolyn"             To:     David Blasi
> <[EMAIL PROTECTED]>, [EMAIL PROTECTED]       
>                     <Carolyn.Pric        cc:     [EMAIL PROTECTED]
> 
>                     [EMAIL PROTECTED]>            Subject:     RE: Transaction
> Delay Question                               
>  
> 
>                     01/15/2002
> 
>                     09:09 AM
> 
>  
> 
>  
> 
> 
> 
> 
> 
> David:  A WEDI task force is completing work on a form recommended to be
> used to file for a delay.  Once completed, the recommendations must be
> approved by the WEDI Board, and then -- hopefully-- by CMS.  Lots of folks
> have been working on this form, and the draft form is VERY SIMPLE to
> complete. At this point, it is my understanding that each entity would be
> responsible for filing their own compliance plan.  I'll bring  that
> question
> up in our conference call this week, and CMS will ultimately have to
> decide
> that one, but I think each entity will have to file for themselves. If the
> WEDI form is approved, it will be quite simple to complete in about 10
> minutes MAX.  With regard to the question of whether a compliant payor
> will
> have to file for a delay due to receiving non-compliant transactions from
> providers who have filed for delay--that question is still pending with
> CMS,
> and will be answered in a FAQ as soon as possible.  Carolyn Price
> 
> -----Original Message-----
> From: David Blasi [mailto:[EMAIL PROTECTED]]
> Sent: Tuesday, January 15, 2002 8:53 AM
> To: [EMAIL PROTECTED]
> Cc: [EMAIL PROTECTED]
> Subject: Re: Transaction Delay Question
> 
> 
> I'm assuming that those entities moving forward would still file a plan
> for the extension.   Obviously it will be a good plan, because you're in
> effect saying "Done".  But, this will allow for correcting
> implementation problems, working with entities that are still using
> non-standard, etc.  I guess my point is that unless you have the ability
> to not do business with certain entities and cut off all non-compliant
> entities, you will have to file a plan for the extension.
> 
> Also, I would propose to the group (HHS representatives mostly) that
> there should be an option for a mass filing for multiple plans.  For
> example, a service provider could file on behalf of all its client
> plans.  Similar to pension plan volume filers.
> 
> 
> >>> "Jan Root" <[EMAIL PROTECTED]> 01/15/02 10:23AM >>>
> Cynthia
> I'm with you.  The payers here in Utah who see a business advantage in
> the HIPAA
> transactions are going ahead with their original schedules for
> implementation by October
> 2002.  The reality is that they may not make that deadline for all the
> transactions but
> they're certainly going to try.
> 
> We tend to get focused on the problems with HIPAA but in the larger
> scheme the HIPAA
> transactions, flawed as they are, make good business sense.  All
> initial implementations
> are flawed but if we waited until they were perfect we'd never get
> anywhere!
> 
> Jan Root
> 
> Cynthia Korman wrote:
> 
> > Major payers who are farther along in their preparations will not
> > necessarily want to delay.  Or, their project plan for
> implementation
> > (required for the application to delay) could call for a phase-in of
> the
> > standards - they may want to stay "on schedule" with one or several
> large
> > providers with whom they have a good relationship and with whom they
> want to
> > start working directly rather than through a clearinghouse...or, they
> may
> > want to add support for a new transaction (Claim Status?  278?) as
> part of
> > an administrative cost-cutting plan, and so may want to stay
> "on-schedule"
> > with providers or clearinghouses who are also "on-schedule"...
> >
> > Individual "transaction senders" sharing with their big partner
> "transaction
> > receivers" information re: how they're addressing the delay option
> could
> > give logic to the whole thing...provide for good planning and
> execution...
> >
> > Cynthia Korman
> >
> > ----- Original Message -----
> > From: "Scott Sallyards" <[EMAIL PROTECTED]>
> > To: <[EMAIL PROTECTED]>
> > Sent: Tuesday, January 15, 2002 9:28 AM
> > Subject: Re: Transaction Delay Question
> >
> > > Can anyone tell me if they think that this issue is industry wide,
> now
> > that
> > > organizations can apply for a delay? Will the payors accommodate
> the needs
> > > of the providers (even though it is the providers responsibility).
> I am
> > > working with some providers and we trying to determine when will be
> the
> > best
> > > time to flip the (transaction) switch.
> > >
> > > Scott
> > >
> > > ----- Original Message -----
> > > From: Christopher J. Feahr, OD <[EMAIL PROTECTED]>
> > > To: <[EMAIL PROTECTED]>
> > > Sent: Sunday, January 13, 2002 10:12 AM
> > > Subject: Re: Transaction Delay Question
> > >
> > >
> > > > Until the deadline (any payor's deadline), that particular payor
> can
> > > > legally refuse to conduct a TX as standard even if the provider
> requests
> > > > that it do so.  It certainly doesn't HAVE to refuse, but it can.
> So the
> > > > provider's options are exactly the same as they are today...
> figure out
> > > how
> > > > to create the format that the payor WILL accept directly or go
> through a
> > > > clearinghouse.  The costs for both options would have to be borne
> by the
> > > > provider... right up until the Payor's compliance deadline.
> After that,
> > > if
> > > > that payor is still not ready and still requires a CH to
> translate std.
> > to
> > > > proprietary, then the PAYOR will have to pay for the provider's
> > > translation
> > > > service.
> > > >
> > > > (keeping track of this looks like a major pain for the CH)
> > > > -Chris
> > > >
> > > > At 08:22 PM 1/9/02 -0500, Paul Costello wrote:
> > > >
> > > >
> > > > >What are the business implications of the following scenario
> that
> > occurs
> > > > >on October 17, 2002:
> > > > >
> > > > >I am a health plan and I already filed for the extension (I only
> have
> > the
> > > > >capability to accept non-standard formats).
> > > > >
> > > > >One of my trading partners (Provider ABC) purchased a whole new
> health
> > > > >information system that is 100% HIPAA compliant and only has
> the
> > ability
> > > > >to conduct electronic transactions in the HIPAA standard
> format.
> > > > >
> > > > >Since I (as the health plan that filed for the extension) can
> not
> > accept
> > > > >standard transactions yet, and my trading partner (who just
> purchased a
> > > > >HIPAA-compliant HIS) can only send standard transactions, what
> happens?
> > > > >
> > > > >Am I, as the health plan who can not accept standard
> transactions,
> > > > >responsible for routing those transactions through a
> clearinghouse, or
> > is
> > > > >it the responsibility of the provider?  What other solutions
> exist?
> > > > >
> > > > >It seems like this situation, and many variations like it, will
> become
> > > > >problematic after October 16, 2002.
> > > > >
> > > > >Any thoughts are appreciated.
> > > > >
> > > > >Thanks,
> > > > >Paul
> > > > >
> > > >
> >**********************************************************************
> > > > >To be removed from this list, go to:
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> > > > >and enter your email address.
> > > >
> > > > Christopher J. Feahr, OD
> > > > http://visiondatastandard.org
> > > > [EMAIL PROTECTED]
> > > > Cell/Pager: 707-529-2268
> > > >
> > > >
> > > >
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> > > >
> > >
> > >
> > >
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