Here's a quote copied and pasted from Appendix A of the 837I IG that I suspect appears in all the HIPAA IGs:
Section: A.1.5.2 Functional Acknoledgement, 997 Paragraph 3 reads: "As with any information flow, an acknowledgment process is essential. If an 'auto-matic' acknowledgment process is desired between trading partners then it is rec-ommended that the 997 be used. Unless named as mandatory in the Federal Rules implementing HIPAA, use of the 997, although recommended by the authors, is not mandated." Best regards, Bill Chessman Peregrine Systems, Inc. -----Original Message----- From: Rachel Foerster [mailto:[EMAIL PROTECTED]] Sent: Saturday, April 20, 2002 6:00 AM To: [EMAIL PROTECTED] Subject: RE: Clarification: Compliance with x12 vs. HIPAA IG Cynthia, your read of how the 997 may be used is correct. But I don't think (I'm at an airport without access to the guides) the HIPAA guides make the use of the 997 **required**....thus, my opinion that it's not. Rachel -----Original Message----- From: Cynthia Korman [mailto:[EMAIL PROTECTED]] Sent: Saturday, April 20, 2002 6:03 AM To: [EMAIL PROTECTED] Subject: Clarification: Compliance with x12 vs. HIPAA IG Sorry to muck up the listserve, but I wanted to clarify my earlier e-mail below...Re: the IG 997 references, 837I section 2.6.1 (p. 40) does NOT restrict mandate for use of 997 to batch mode...the quote is: "The Functional Acknowledgement (997) transaction is used as the first response to receiving an 837. The 997 informs the 837 submitter that the transmission arrived. In addition, the 997 can be constructed to send information about the syntactical quality of the 837 transmission." So there IS a mandate for the 997, but flexibility in how it's applied... Cynthia Korman, Principal Strategic System Solutions, LLC 973 394-9529 [EMAIL PROTECTED] www.healthcare-systems.com ----- Original Message ----- From: "Cynthia Korman" <[EMAIL PROTECTED]> To: <[EMAIL PROTECTED]> Sent: Saturday, April 20, 2002 6:16 AM Subject: Re: Compliance with x12 vs. HIPAA IG > Rachel, thanks for the pointer to the 997 in the IGs. I especially like the > note that says that the Functional Acknowledgement shall not be > acknowledged, thereby preventing an infinite loop :^> (My paraphrase...) > > My read of the IGs is that they DO mandate the 997. (At least the 837I for > batch mode - Section 1.3.2 p. 14, and, more significantly, in section > 2.6.1, p. 40 ) I also saw the "not limited to" aspect of the mandate > (Section 1.4 p. 14). and therefore appreciate your point re: the 824... > > My, but these documents are large...thank goodness they're well written! > Cynthia > > Cynthia Korman, Principal > Strategic System Solutions, LLC > 973 394-9529 > [EMAIL PROTECTED] > www.healthcare-systems.com > ----- Original Message ----- > From: "Rachel Foerster" <[EMAIL PROTECTED]> > To: <[EMAIL PROTECTED]> > Sent: Friday, April 19, 2002 10:35 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. > > > > But, please read my lips: The HIPAA electronic transactions rules and the > IG > > DO NOT require nor mandate nor prohibit the use of the 997, the 824 or any > > other error reporting mechanism, even fax, email, snail make or phone. > Thus, > > Mary Payer is not in non-compliance for not providing a 997, but she > > certainly isn't playing fair by either accepting, conducting and > processing > > non-compliant transactions without notifying Bob Provider or by not > > rejecting non-compliant transactions. > > > > I am truly puzzled by the industry seems to be struggling with this > concept. > > This is fundamental electronic data interchange tracking, auditing and > > reporting and it existed long before we started using the X12 standards. I > > wrote and supported systems in the early 1990's using flat file formats > with > > hospitals for medical products procurement in which we provided this type > of > > tracking, ack'ng/nack'ng and so on. It just plain good systems design. > > > > 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? > > > > > > > > > > ********************************************************************** > > 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. 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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. ********************************************************************** 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.
