RE: Computer-to-computer HTML under the transaction regulation

[Owens, Kris]

Rishel,   If I am reading between the lines in your communication - you have made the statement that if we are doing DDE we must also do REAL-TIME x-12.  Last I understood this was still up for debate - I understood that yes, we must offer x-12 transactions, but not necessarily "real-time" - this centered on the discussion about what an incentive is.  Has there been clarification from HHS on this?  Peter Berry in his white paper on DDE transactions poses the question to HHS, but I was not aware of a response.   Kris Owens Senior Project Manager - HIPAA Project Presbyterian Healthcare Services 505/923-8108 [EMAIL PROTECTED] HIPAA means a higher level of healthcare. -----Original Message----- From: Rishel,Wes [mailto:[EMAIL PROTECTED]] Sent: Monday, March 25, 2002 10:35 PM To: [EMAIL PROTECTED] Subject: Computer-to-computer HTML under the transaction regulation A not uncommon way of sending "real-time" transactions today computer-to-computer is to have the sending computer send HTML to a health plan's web server, simulating what would have come from a person using a Web browser to access the health plan's Web server.   This is not acceptable under the transaction regulation.   However, what happens if the Web server is being run by a clearinghouse, which is converting the input to X12 and sending it to the payer? I think that MedUnite does a bunch of this, among other clearinghouses. It appears that that would be legal, right? This would not be legal under the DDE exception, which seemingly applies only to provider-payer interactions, but it would be legal under the general definition of a clearinghouse which can accept data in any old format that it wants and then convert it to the mandated format.   What about the reverse? Can a clearinghouse accept standard X12 transactions and deliver them to a health plan using HTML? I think that the answer once again is yes, because a clearinghouse can accept a standard format and deliver it in whatever format it wants.   So then, what happens if the clearinghouse converts the machine-to-machine HTML to X12 "for one microsecond" and then converts the X12 back to HTML and forwards it to the payer's web server. This appears to be legal, so long as the DDE web screens in use are fully the equivalent of the X12 transactions. This appears to be a loophole that would permit providers who have been sending "pseudo EDI" machine-to-machine in this manner to continue to do so.   One might ask, "why would anyone want to do it this way when it would be more efficient and robust to use X12?" Indeed, the main incentive to do this goes away when health plans start offering "real time" X12 transactions, which they must if they want to continue to offer DDE.   The only reason that I can think of is that where providers are already sending transactions this way it would be easier in the short term to modify the code to match a fully compliant DDE Web Server than to buy, configure, and debug a software mapper. Very short-sighted, but the question does come up.       ********************************************************************** 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. --- PRESBYTERIAN HEALTHCARE SERVICES DISCLAIMER --- This message originates from Presbyterian Healthcare Services or one of its affiliated organizations. It contains information, which may be confidential or privileged, and is intended only for the individual or entity named above. It is prohibited for anyone else to disclose, copy, distribute or use the contents of this message. All personal messages express views solely of the sender, which are not to be attributed to Presbyterian Healthcare Services or any of its affiliated organizations, and may not be distributed without this disclaimer. If you received this message in error, please notify us immediately at [EMAIL PROTECTED]