compliance with x12 vs. HIPAA IG

[Cynthia Korman]

Title: RE: questions on the appropriate way to reply when there are error in a transaction request

Regarding Mike's comment below: "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?. "  My understanding is that one CAN get the X12 right and be out of compliance from a HIPAA perspective.  Specifically, in the HIPAA Implementation Guides, the data element attributes to the right of the data element names and descriptions are X12; the "usage" column to the left of the de names/descrips are HIPAA-specific.  The two sometimes contradict, in which case the "usage" column on the left takes precedence.    For example: 837P IG, p. 172 shows "Claim Filing Indicator Code" as "O" or Optional from the X12 perspective, but NOT USED from the HIPAA perspective.  That same page shows "Health Care Service Location Information" as Optional from the X12 perspective, but REQUIRED from the HIPAA perspective.   To summarize, my understanding is that it's the left hand column that's the bible when it comes to USAGE (Required/Situational/Not Used).  If anyone believes that to be off base, please advise!    Can the 997 report errors in (HIPAA-specific) USAGE?  Thanks in advance...    Cynthia Korman, Principal Strategic System Solutions, LLC 973 394-9529 [EMAIL PROTECTED] www.healthcare-systems.com ----- Original Message ----- From: Augustine, Mike To: '[EMAIL PROTECTED]' Sent: Thursday, April 18, 2002 3:16 PM 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/. 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