The HIPAA initiative strikes me as having some similarity to what happened in the EDI world a few years back with the failure of XML as a replacement for EDI. XML was touted and sold as a magic problem solver, however, it turned out that the real challenge with integration is not in the messaging format; it is that disparate backend systems have different business requirements.
HIPAA seemes to me to be overly ambitious in this assumption that a standard document is a magical solution to disparate business systems and processes. I have not seen business revamping their entire processing systems to conform to HIPAA requirements, but rather external patches (tape, paperclips and chewing gum). It seems that without the "mass upgrade to every provider's desktop software" which would equate to a standard business process across the board, how will HIPAA ever work? And the same should extend to the backend systems of the major payors. Without these commitments, this is going to be a long rough ride. Anthony Beecher EDI consultant (disclaimer: personal comments, with no relationor relevance to my employer) -----Original Message----- From: Hayward, Donna M B230 [mailto:[EMAIL PROTECTED]] Sent: Thursday, January 31, 2002 10:07 AM To: '[EMAIL PROTECTED]' Subject: RE: Free Form Text Field Usage Tom, I do agree with you for the most part and we shouldn't look to change the meaning or intent of the implementation guide. To your point if it isn't included in the guide it should not be used. For example, note #1 on page 185 of the dental implementation guide states, "Required when: (1) State regulations mandate information not identified elsewhere within the claim set; or (2) to report periodontal charting information." Should we then take the approach that periodontal information shouldn't be sent as there isn't a placeholder defined in the guide? Somehow I don't envision a mass upgrade to every provider's desktop software that will require only HIPAA required fields and will remove all others. Assuming I'm correct, providers may likely continue to send the same data they are sending today and at least in our case, the clearinghouse will provide the roll of HIPAA data collector. If the data is available and it would ultimately benefit the provider if the payer continues to receive the data, it seems like a no brainer to me. But again, it would have to be sent solely on a voluntary basis. FYI, you'll be interested in knowing my DSMO request has been honored and rendering provider address will be added to the next version of the dental guide. I now need to keep my fingers crossed this particular version will be adopted under HIPAA. As for responses, I did receive some direct responses from others and interestingly enough they have taken the same approach with the NTE section as we have. I think we're all trying to do the right thing by HIPAA but still remain able to conduct business with some semblance of normalcy. Donna M. Hayward -----Original Message----- From: Tom Drinkard [SMTP:[EMAIL PROTECTED]] Sent: Wednesday, January 30, 2002 4:52 PM To: [EMAIL PROTECTED] Subject: RE: Free Form Text Field Usage 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. 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