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.
