One little wrinkle from http://aspe.hhs.gov/admnsimp/q0533.htm:
Question: "If a health care provider electronically conducts a
non-compliant transaction (transmits an old National Standard Format
or a proprietary format) directly to a health plan after the
transaction regulation compliance date, and the health plan accepts
and processes the non-compliant transaction, who is in violation of
the regulation? Is it the health care provider or the health plan?"
Answer dated 11/2/2001: "If a health care provider electronically
conducts a non-standard transaction with a health plan after the
transaction regulation compliance date, the health care provider and
the health plan are both out of compliance. Section 162.923(a) of the
rule requires a covered entity conducting an electronic transaction
for which a standard has been adopted with another covered entity to
conduct it as a standard transaction."
Dave Feinberg
Rensis Corporation
206-617-1717
[EMAIL PROTECTED]
----- Original Message -----
From: "Rachel Foerster" <[EMAIL PROTECTED]>
To: <[EMAIL PROTECTED]>
Sent: Friday, April 19, 2002 7:35 PM
Subject: RE: Compliance with x12 vs. HIPAA IG
>From a business perspective, I'd agree that Mary Payer didn't do Bob
Provider a favor by not reporting the non-compliant condition.
<snip>
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: Barton, Joe [mailto:[EMAIL PROTECTED]]
Sent: Friday, April 19, 2002 6:21 PM
To: '[EMAIL PROTECTED]'
Subject: RE: Compliance with x12 vs. HIPAA IG
Said well, but anyone who does not inform the person with an 824 or
997 back is non-compliant, nor a good business practice. I remember
almost 2 years ago, during a class presented by the feds, that if
there are errors, but those errors will not prevent proper processing
for payment by the payers payment system, that the payment shall not
be delayed until the transaction is resent in it's fixed format. The
sender must be notified that a non-compliancy issue exits. Mary did a
no no by not sending information back to the sender of the error.
Thoughts?
Joe
-----Original Message-----
From: William J. Kammerer [mailto:[EMAIL PROTECTED]]
Sent: Friday, April 19, 2002 4:06 PM
To: [EMAIL PROTECTED]
Subject: Re: Compliance with x12 vs. HIPAA IG
Let's see: Bob Provider refrains from testing his transactions for
HIPAA compliance and sends any old slop to Mary Payer. Mary, being
generous, reads "between the lines," processes the non-compliant
transaction and pays the claim. Mary does this a couple of times for
Bob, and never even sends back a negative 997, an 824 application
advice or even an e-mail to indicate her displeasure. Bob, not
knowing any better -thinking he's doing everything right 'cause the
checks keep flowing - gets more brazen and throws a doozy at Mary.
This time, finally, Mary is upset - so much so that she says enough is
enough, and finally tells Bob off.
Now, except for the most trivial syntax "violations" - like CR/LF
pairs used as segment terminators, trailing spaces, and things of that
ilk - is it really wise for Mary Payer to forgo at least warning Bob
that he's screwing up? Is it really fair that now she tells him to
fix his stuff? - even though he may never have known what he was doing
wrong up to this point? And this may be happening at the worst
possible time for Bob when his volume is really up and he's depending
on those payments.
Or even worse, wouldn't it be really nasty of Mary to inform on Bob to
the HIPAA Stasi, if he were to persist in sending the errant
transactions? They're going to ask why she didn't nip this in the bud
the first time it happened and fine poor old Bob for all the previous
"HIPAA infractions." The only justice (East German style) here would
be if the tables were turned on Mary and she were fined for all the
malformed transactions she accepted from Bob in the first place!
I would say Mary Payer is best off if she puts her foot down the first
time she sees a non-trivial problem (i.e., an X12 syntax violation or
a HIPAA inconsistency). She's under no obligation to "fix" things for
Bob Provider, and is indeed better off if she takes a hard-line
stance.
William J. Kammerer
Novannet, LLC.
+1 (614) 487-0320
----- Original Message -----
From: "Barton, Joe" <[EMAIL PROTECTED]>
To: <[EMAIL PROTECTED]>
Sent: Friday, 19 April, 2002 05:30 PM
Subject: RE: Compliance with x12 vs. HIPAA IG
If a transaction does fail HIPAA edits, but sufficient information is
available to process the transaction such as a claim, can we still
process and pay?
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