Kris makes a very important differentiation. It
is the 'ability to create a standard transaction' that is certified. This
'ability' is very important. It is also important to know what specific
'capabilities' within the 'ability' have been demonstrated to a certification
system. This is because there are so many permutations of compliant
transactions within the complex health care environment. Remember that
systems or applications that have the 'ability' to generate HIPAA compliant
transactions could also be used to create non-compliant transactions -- there is
simply no way around this. So, here's an
attempt at a sequence of this:
1. The 'ability' of an application or system (direct
or clearinghouse) is certified to a detailed level. This
certification is useful for covered entities to know which application/system to
use or buy. (It may or may not be necessary depending on whether such a
decision is being made.)
2. The application/system is then implemented by/for
a covered entity.
3. Then, the covered entity gets their own
transactions certified (direct or clearinghouse) to a detailed level to
determine that the application/system was implemented successfully. Again,
it is the 'ability' of the covered entity to create HIPAA compliant transactions
using a specific application/system that is certified. And it is
important that the specific 'capabilities' of the 'ability' be certified, so the
covered entity can be sure they are generating HIPAA compliant transactions for
all of the applicable permutations (e.g., for institutional claims: Inpatient,
Outpatient, Rehabilitation, Mental Health, etc.; for professional claims: Office
Visit, Anesthesia, DME, Oxygen, etc.).
Hope this helps,
Larry
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