Hmmm.  I was reading it differently, but have the same DDE vs. forced realtime 270/271 
issue.   

We have had some similar discussions on a clearing house representing both the payor 
and the provider...offering both the service of processing in a non-compliant 
application interface format.  

They can offer that service but it must be in a hipaa x12 format somewhere, even if 
just a microsecond.  I believe the DDE exemption is eliminated due to the computer to 
computer activity. 

A hovering question is what to do with an existing real time transaction (we called a 
DDE) that doesn't qualify for a DDE exemption because it is computer to computer.  
Your solution is great to have the payor upgrade the proprietary format enough to have 
a clearinghouse form a 270/271 for a microsecond.  Does that force offering a realtime 
270/271?  Hopefully not.  We really do need an answer because of the sizeable impacts. 
 

I'm really not talking about a loophole.  I'm suggesting upgrading existing realtime 
content while forming a batch 270/271 which is a lot before the deadline and a great 
launching pad for the next round. 
Peter Barry may be able to weigh in on this fuzzy issue. 



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