Hi Donna, I've not yet seen a response to your question, so I'll take a shot. Hopefully others will agree or disagree as well.
I don't think that you can put a specific data request into a trading partner agreement unless that data is already in the implementation guide. Section 162.915(d) of the Final Rule on Transactions and Code Sets (page 50368) says, "A covered entity must not enter into a trading partner agreement that would do any of the following:" << (a)-(c) omitted >> (d) Change the meaning or intent of the standard's implementation specification(s)." To me, this means that you can't go outside of the existing data elements. The Rendering Provider Address is not a part of the HIPAA-compliant 837 Dental Claim. Unlike the Professional Claim, there are no provisions for using the Facility Address, either. To request this data anyway would "change the meaning or intent of the standard's implementation specification(s)", in my opinion. If you make this request of the clearinghouse, then you have delegated the problem, but have not solved it. The clearinghouse has no access to the Rendering Provider Address either, since the clearinghouse must put the transaction into a standard format at some point. Also, if a dental office sends a HIPAA-compliant Dental claim to a clearinghouse, then the clearinghouse would only have the allowed data items in the transaction. The clearinghouse cannot invent the data, so this does not solve the problem. Having said this, the note segments can contain free-form text that just might happen to be a Rendering Provider Address. Or, the notes could contain a collection of pocket depths, or many other things. I would hate to see anything that would force the dental office to send one set of information in the notes to payer A, something else in the notes to payer B, etc. This would seem to me to be a violation of the intent of the HIPAA Administrative Simplification law. Just as long as the trading partner agreement doesn't ask (demand?) anything that is beyond the scope of the HIPAA transaction, the provider could pass this information in the notes, but it would be strictly voluntary (and somewhat unlikely, in my opinion). Tom Drinkard EDIT (678) 795-1251 (voice) (678) 795-1575 (fax) [EMAIL PROTECTED] -----Original Message----- From: Hayward, Donna M B230 [mailto:[EMAIL PROTECTED]] Sent: Monday, January 28, 2002 1:09 PM To: '[EMAIL PROTECTED]' Subject: Free Form Text Field Usage Can the clearinghouse and payer enter into a trade agreement to use the NTE free form remarks section to pass data? The question is a result of data that is not included in the 837dental guide, in this particular case it stems from lack of rendering provider address, but conceptually it could apply to other data as well. This would be a situation where it wouldn't be required of the provider nor would claims be rejected if the information were not provided. It would simply be a situation where if the provider chose to continue to supply and we would like to continue to receive, can the NTE be used to pass the data? I'd appreciate any opinions. Thank you. Donna M. Hayward A CIGNA HealthCare - EDI GATEWAY HIPAA Project Manager * Bloomfield: 860.226.3134 Ntwk: 572-3134 Fax: 860.226.7573 * e-mail: [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]> "Passionately committed to making every experience with CIGNA HealthCare positive and highly satisfying. For everyone. Every time." The information contained in this e-mail may be confidential and is intended solely for the use of the named addressee. Access, copying or re-use of the e-mail or any information contained therein by any other person is not authorized. If you are not the intended recipient, please notify us immediately by returning the e-mail to the originator. Confidential, unpublished property of CIGNA Do not duplicate or distribute Use and distribution limited solely to authorized personnel (c) Copyright 2002 by CIGNA ---------------------------------------------------------------------------- -- CONFIDENTIALITY NOTICE: If you have received this e-mail in error, please immediately notify the sender by e-mail at the address shown. This e-mail transmission may contain confidential information. This information is intended only for the use of the individual(s) or entity to whom it is intended even if addressed incorrectly. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. Copyright (c) 2002 CIGNA ++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ ********************************************************************** To be removed from this list, send a message to: [EMAIL PROTECTED] Please note that it may take up to 72 hours to process your request. ********************************************************************** To be removed from this list, send a message to: [EMAIL PROTECTED] Please note that it may take up to 72 hours to process your request.
