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: Augustine, Mike [mailto:[EMAIL PROTECTED]]
Sent: Thursday, April 18, 2002 2:17 PM
To: '[EMAIL PROTECTED]'
Subject: RE: questions on the appropriate way to reply when there are error in a transaction request
Rachel,
I think I follow what you are proposing and it makes sense to a point, but I don't totally get it. I would have to also contend that the HIPAA IGs are a subset of X12. If you can't get the X12 right, you're non-compliant, right?. You may be able to distinguish, but what real value is there in doing so?Also, the large scale translation software that my client has purchased has HIPAA compliancy checking built in as an optional feature. An incoming or outgoing transaction will be compliance checked and either pass or fail. I'm not thoroughly proficient with the process yet, but I do not believe there is any room for separating X12 compliance from HIPAA compliance. I also believe that the idea is if the compliance check fails, the transaction will be rejected with a 997.
And finally, although your scenario with the 824 in the middle may be correct EDI-wise, isn't a little ironic that the method of reporting HIPAA non-compliance would be with a non-HIPAA mandated transaction? Since there is no HIPAA IG, then you would have to negotiate with each trading partner that you are going to use the 824, and then specifically how it will be populated, and that leads to details in a companion guide, which leads to accepting or sending different 824 configurations for different trading partners... It seems to continue some of the problems that having the industry standard are supposed to reduce or eliminate. Perhaps the 824 should have been included in HIPAA, but since it hasn't should we really move to standardize on it?
I may be just missing some of the big picture. Please help me out with where the flaws are in my reasoning.
Mike Augustine
Principal, SILC, Incorporated-----Original Message-----
From: Rachel Foerster [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, April 16, 2002 11:13 PM
To: [EMAIL PROTECTED]
Subject: RE: questions on the appropriate way to reply when there are
error in a transaction request
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
**********************************************************************
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.
==================
The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/.
Posting of advertisements or other commercial use of this listserv is specifically prohibited.
**********************************************************************
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.
=====================================================
The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/.
Posting of advertisements or other commercial use of this listserv is specifically prohibited.
