I think this entire thread points up a potential gray area that's going to
make HIPAA compliance and cooperation a little more difficult:  824 is not
mentioned in any of the published IGs (draft or final) while the 997 is
mentioned in all of them.  Since there's no recommendation for a common
implementation of 824, there's going to be...well...chaos...

Issues for the error reporter (creating 824s):

> Which version of 824 should I use?
> Which types of problems should I catch or not catch?
> How much human intervention will this require?  (I love the TED (technical
description) segment...it includes 60 bytes of free-form message to help
describe the problem!!!)
> How detailed should the error reporting be for any given incursion?

Issues for the error report recipient (created the original data in error):

> Which version of 824 did trading partner X use?
> How much of the error fixing can I automate (and how much time will that
take)?
> E-gads! Yet another transaction set to deal with...I'm already underwater
with the rest of the HIPAA ballast!

These are things that everyone needs to think about.  I am not saying the
824 should not be used--far from it!  I'm just saying that the lack of a
HIPAA specific IG leaves the field open so that every trading partner can do
their own thing--and I'm sure they will!  8-)

Finally, if an 824 IG that fit the HIPAA world could be created (a big if
and an arduous task no doubt), would that be under the auspices of X12N or
some other subcommittee?

Best regards,
Bill Chessman
Peregrine Systems, Inc.

-----Original Message-----
From: Sujay Pidara [mailto:[EMAIL PROTECTED]]
Sent: Wednesday, April 17, 2002 7:47 AM
To: [EMAIL PROTECTED]; [EMAIL PROTECTED]
Subject: RE: questions on the appropriate way to reply when there are
error in a transaction request


In the same vein of separation, it will be helpful to keep the communication
of syntactical errors separate from Application pre-edit errors/semantic
errors. From what I read in the "Front-end edits" white paper on SNIP-WEDI,
it also recommends separating IG level results from the Application pre-edit
results.  X12 also provides communication for syntactical errors separately
through 997.

Compliance to the IG syntax is necessary under HIPAA. Application pre-edit
errors at the moment are payer specific. Lately, I read that 820 version is
geared more towards semantic and maybe also application pre-edit errors. If
that is the case then it will mix syntactical errors with application
pre-edit errors.

Sujay Pidara

Radicle Incorporated

>>> [EMAIL PROTECTED] 04/16/02 10:13PM >>>
Don,

All things being equal (and when does that ever occur!) I would tend to
agree with you. On the other hand, HIPAA is especially unique in that there
are federal economic penalties that apply for covered entities that conduct
non-standard transactions.

Now, we've all heard that HHS/CMS isn't anxious to wield the economic ax,
but if/when penalties will apply (and I would contend that legally that
would be either on/after 10/16/02 or 10/16/03) then there must be a clear,
unambiguous boundary between X12 standards compliance and HIPAA compliance.

Mixing some HIPAA "syntax" into the 997 does not give either the receiver,
which applies the edits, nor the originator, which created the non-complying
transaction, a clear statement of whether the transaction fails X12
compliance or HIPAA compliance. I can argue that X12 non-compliance would
not subject the covered entity to any federal penalties, but most certainly
HIPAA non-compliance would.

It's for these reasons that I continue to argue strongly for keeping the
boundary clear and unequivocal. If we don't, the lawyers will have a
wonderful day in court when some of this gets there....and I would bet a
day's consulting fee that it will....sooner or later.

If this gets "mushed" together (that's a technical term!!!) sorting it out
becomes quite costly. Why not bite the bullet now, develop the necessary
enabling functions in the EDI management systems and move on. As a former
software developer I could even see where it could be a strong competitive
advantage for an EDI management system's vendor to offer a two-pass
validation totally within the EDI interpretation/generation function,
automatically applying two maps with the first one being vanilla X12
compliance and the second HIPAA guide compliance. This is not rocket science
program design nor logic.....it's actually not that much different from the
old two-pass code compilers in the old days. To me, this would be a
no-brainer added new HIPAA feature that could blow my competitors away....if
I was an EDI management system developer, that is.

Rachel

Rachel Foerster
Principal
Rachel Foerster & Associates, Ltd.
Professionals in EDI & Electronic Commerce
39432 North Avenue
Beach Park, IL 60099
Phone: 847-872-8070
Fax: 847-872-6860
http://www.rfa-edi.com 


-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] 
Sent: Tuesday, April 16, 2002 4:08 PM
To: [EMAIL PROTECTED] 
Subject: RE: questions on the appropriate way to reply when there are
erro rs in a transaction request



Well, not to be too controversial, but I think there is a reasonable
compromise here.  I agree with Rachel that 997 should be limited to X12
syntax and code set lists, and so on.  I agree that when we start to
introduce X12N Implementation Guide edits it will be hard to know where to
stop.  But, I suggest there are some very reasonable Implementation Guide
edits that could be added to the 997.  In fact, I believe the 997 would be
a better place to handle some edits because it will be done on the front
end rather than the back end of processing and wouldn't require a new
implementation guide to implement, which will be needed for the 824.

My suggestion is where X12N transactions have limited (reduced) the code
set list for certain data elements within certain segments or transaction
loops, that translators could easily do this edit and report errors with
the 997.  We're still reporting what code values are permitted, but we're
restricting the list to a subset of what X12 permits.  This seems
reasonable to me.  This would not really enter into situational as much as
just what the health care industry has defined to be a logical set of
values for our industry.

Don




[EMAIL PROTECTED] on 04/16/2002 01:20:41 PM

Please respond to <[EMAIL PROTECTED]>

To:   <[EMAIL PROTECTED]>
cc:
Subject:  RE: questions on the appropriate way to reply when there are erro
      rs in a transaction request



Ditto -- Bruce





                    Bill Chessman
                    <bill.chessman@pere        To:
"'[EMAIL PROTECTED]'"
                    grine.com>                 <[EMAIL PROTECTED]>
                                               cc:
                    04/16/2002 11:39 AM        Subject:     RE: questions
on the appropriate way
                    Please respond to          to reply when there are erro
rs in a
                    transactions               transaction request






I think the big question is, once you start, where do you stop?  The idea
of
situational and required elements being flagged as missing in 997 seems
reasonable to me, but once we start adding these things, there'll always be
something else.  I think that Rachel's guideance was right on target.  I
know that there's a lot of resistance to 824 vs. 997, but there's a
legitimate distinction between application-specific (ie., HIPAA) problems
and mechanical EDI problems (IMHO).

I also note that there's an implementation of 997 included in the
appendices
of each of the HIPAA IGs.  I haven't spent a lot of time, but I imagine
they're all pretty much the same (boilerplate, I hope).  This presents the
potential that, at some point going forward--if it should be decided to
report HIPAA IG failures via 997, the IGs might start to vary their
implementations of 997...that would be no fun.

Best regards,
Bill Chessman
Peregrine Systems, Inc.

-----Original Message-----
From: Ajay K sanghi [mailto:[EMAIL PROTECTED]] 
Sent: Tuesday, April 16, 2002 3:42 AM
To: [EMAIL PROTECTED] 
Subject: RE: questions on the appropriate way to reply when there are
errors in a transaction request



My view is that to the maximum extent possible, translators should handle
HIPAA guide validation failures using 997 and not stick to just X12
"standard" syntax validation.

If a "situational" element/segment, which is "required" in certain
condition
is missing, 997 should generate "Mandatory Data Element/Segment Missing"
code for such elements/segments  and likewise.

Ajay

 -----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]]On 
Behalf Of Rachel Foerster
Sent: Tuesday, April 16, 2002 4:11 AM
To: [EMAIL PROTECTED] 
Subject: RE: questions on the appropriate way to reply when there are
errors
in a transaction request





Jim,

When and on what basis to reject is basically a business/risk decision on
the part of the receiver. However, I take the following view:

1. The entire interchange must pass the full X12 syntax validation. If
errors, fail and report via 997.

2. If interchange passes X12 syntax then apply HIPAA guide validation
rules.
If a transaction within the interchange does not comply with guide, fail
the
transaction and report via the 824. Keep in mind that validation also
includes validating medical and non-medical codes as being valid within the
referenced code set.

3. If transaction passes HIPAA guide validation, pass transaction data to
internal application and apply internal business rules. Report pass/fail
using various mechanisms, i.e., 271 response to 270, 277 response to 276,
and so on.

But that's just one person's viewpoint.

Rachel
Rachel Foerster
Principal
Rachel Foerster & Associates, Ltd.
Professionals in EDI & Electronic Commerce
39432 North Avenue
Beach Park, IL 60099
Phone: 847-872-8070
Fax: 847-872-6860
http://www.rfa-edi.com 
-----Original Message-----
From: Jim Moores [mailto:[EMAIL PROTECTED]] 
Sent: Monday, April 15, 2002 7:55 AM
To: [EMAIL PROTECTED] 
Subject: RE: questions on the appropriate way to reply when there areerrors
in a transaction request





Hi Rachel,

  I agree.  However, do you just reject the one claim in error or do you
just reject the entire batch of claims in the transmission (assuming that
you have gotten other transactions in the transmission)  or do you reject
the entire transmission?  In some cases, I think that the entire
transmission is appropriate... like when the loop structure is so corrupt
that you can't parse it.  But, what about the area between that and the
perfect transmission?



Jim Moores - HIPAA Team Leader - Privacy
Antares Management Solutions
23700 Commerce Park Road
Beachwood, Ohio   44122-5832

[EMAIL PROTECTED] 
Phone: (216)292-1605
Fax:      (216)292-1619


>>> [EMAIL PROTECTED] 04/13/02 08:30PM >>>
Connie,

If the incoming transactions contains X12 standards syntax errors it must
be
rejected. The correct way to report this rejection is via the 997
Functional
Acknowledgment transaction.

Rachel Foerster
Principal
Rachel Foerster & Associates, Ltd.
Professionals in EDI & Electronic Commerce
39432 North Avenue
Beach Park, IL 60099
Phone: 847-872-8070
Fax: 847-872-6860
http:/www.rfa-edi.com 


-----Original Message-----
From: Connie Lagneaux [mailto:[EMAIL PROTECTED]] 
Sent: Friday, April 12, 2002 1:06 PM
To: '[EMAIL PROTECTED]' 
Subject: questions on the appropriate way to reply when there are errors
in a transaction request



1. If there are actual syntax errors in an incoming X12, what exactly is
the
correct way to respond? By this I mean it is not a valid X12 at all.   We
are unclear as to whether it is appropriate to respond with a 997 vs
something, for example, in a 271 or 277).

2. If there are "logical" errors in an incoming X12, what exactly is the
correct response? By this I mean it is a valid X12 but it does not meet the
HiPAA specs.
Examples:
If 276 - IG 54, 98 - is not set to the code "PR" for payor but to something
else, what do we do? (if we would be receiving requests only from payors)
A
997 response?
If 276 - IG 67, 98 - is not set to "1P" for provider but to something else,
what do we do?  (if we are only expecting 1P) A 997?

3. If there are "business" errors in an incoming X12, what exactly is our
response? By this I mean that the request is both a valid X12 and a valid
HIPAA transaction but contains other errors.
Examples would be an unknown information source (payor), and unknown
provider, etc. Also I think this would include issues like the dependent
given is not a dependent of the given subscriber.

It appears that each level of a 271 has request validation segments /
reject
reason codes in the 270 request.  Are these codes used for business errors
while a 997 is used for other errors? Since the 277 lacks these codes, are
all errors handled using 997s? If so doesn't this stop all further
processing of the 276 transactions in the transmissions?


<<...OLE_Obj...>>
        Connie Lagneaux, RN, BSN, MBA
Senior Business Analyst
5151 E. Broadway Boulevard, suite 1050
Tucson, AZ  85711

Phone (520) 571-1988 ext. 153
Fax     (520) 571-1927
<mailto:[EMAIL PROTECTED]>





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