Tracie, As Jan indicated in her last paragraph, requiring providers to put information in a loop that is different than the definition under HIPAA (in this case there may actually be different billing and pay-to providers) is not allowed. Further, HIPAA specifically prohibits trading partner agreements from, among other things, changing the definition, data condition, or use of a data element or segment in a standard. (162.915)
So, I think that whether there is a contract or not, requiring providers to only use certain of these fields or to use the fields for other than what it is defined as would violate HIPAA. Leah Hole-Curry Fox Systems, Inc. 602-708-1045 >>> [EMAIL PROTECTED] 03/27/02 14:10 PM >>> Tracie I would respectfully add to Tom's comments. I agree with Tom conceptually that the Billing should be the Pay-to (it makes life much easier!), but it is simply not always the case. The "Billing Provider" may or may not be the entity receiving payments. If the Billing provider was always the Pay-to then we wouldn't need two loops. However, that said, nothing in HIPAA prevents you from structuring your contracts with your providers such that the Billing is always the Pay-to. You could even conceivably structure your contracts with your providers so that the Rendering is always the Billing is always the Pay-to. The imp guide doesn't say that these have to be three separate entities. It just says that if they are three separate entities then they should be reported as such. So, the question becomes: who defines who is the billing vs the pay-to vs the rendering? The answer is: the payer-provider contract, and that varies by trading partner (in the absence of a contract, presumably anything goes). So, whether it is kosher to always require your providers to put 'rendering' in the 'billing' and to pay them as such, I would guess depends, in part, on your contractual relationship with them. If you don't have a contractual agreement supporting this request than I would personally agree with your concern that requesting your providers to always enter the "rendering" into the "billing" loop may not be allowable under HIPAA. It might constitute a violation of the HIPAA Transaction and Code set rule which might open you up to fines (sometime in the future). In some ways, what you are proposing may not be an EDI question, it may be a legal question: the Transaction and Code rule specifically prohbits anyone from changing the meaning of any element. By requiring your providers to always put a Rendering in the Billing, someone might argue that you have violated the rule. Anyway, thems my 2 cents. Jan Root ********************************************************************** 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.
