Hi All,
A quick question.... we think that we have a plan on how to handle
837 Adjustments within the limitations of our systems (for now). The
question is... Is it an acceptable solution for HIPAA.
We propose to accept all 837 Adjustments, then do two things:
Dump the 837 Adjustment data to paper for internal use and reject the electronic
version back with an 835. We will then send the paper version of the
adjustment to our "Adjustments Research" unit, where the adjustment will be
researched and, if warranted, acted upon by adjusting the original claim record
in our claims system. This will result in a "debit" and a "credit" 835 to
be generated.
The question is - Are we compliant if what the provider
sees from us (the payer) is:
1) All 837 Adjustments that they send to us are rejected on an
835.
2) For all the adjustments that we accept and act upon, they will
receive 2 835's... (1) a credit of the original claim and (2) a debit with the
changes/adjustments that we accepted (using all the data as sent to use
originally in combination with the changes that we accepted from the
Adjustment 837... not as sent on the adjustments 835 that we rejected).
That would be a total of 3 835s for every one adjustment that
we accept and 1 835 that we don't accept the adjustment.
I can't see anywhere in the regs or IG's that say you have act on an
837 other than (by implication) return an 835. And there is nothing that I
can see where we wouldn't be allowed to send multiple 835's for one
837....
So where is my logic faulty? Any feedback is welcome!
Jim Moores
Jim Moores - HIPAA Team Leader - Privacy
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