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David,
Yes.
If marked not used, that's what it means. Don't use
it...if you do, you're not complying with the law.
Rachel
OK,
the second scenario came in with data that is marked as not used, but my
transaction
processor does not examine segments that are not used... So I am
not even aware that
the
data was there in the first place...
I
assume that it is also a violation of the reg for me to process
that..
Joe,
If you receive a transaction with a segment **that
is included in the HIPAA IG as either required or situational** and you
don't need the data conveyed by that segment, you are **prohibited** under
the Electronic Transaction Final Rule from rejecting the transaction on the
basis that it contains data you don't need to process the claim/transaction.
Thus, if you rejected a complying HIPAA transaction based on the fact that
it contained data allowed by the IG but data that you don't need, you would
be in violation of the regulation.
On the other hand, if you received a transaction
with a segment or element **marked not used** and you did not reject the
transaction based on non-compliance with the IG, you would also be in
violation of the regulation by conducting a non-standard
transaction.
Get the difference?
In either case, you are still free to exercise a
business decision to accept the risk of violating the regulation and thereby
exposing your organization to the penalties for doing so under the
regulation. I would make my business decision only on the advice
of legal counsel.
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
Rachel.
So if
we get a segment that does not related to any business of ours, such
as one that is optional, or even still, one that does not
related to a waivered service claim, we reject the whole claim even if
everything required to process that claim is accurate? Obviously we would
let the provider know that segment is not needed, does that mean bouncing
the claim?
Joe
Joe,
It's your business decision whether to do this or not. You
must evaluate the risk in doing so (possible penalties, etc.) against the
risk of rejecting and then determine the business impact for either
option. Make the business decision and then act on it.
The regulation says that a covered entity must conduct a
transaction covered by the rule as a standard transaction. Non-compliant
subjects the covered entity to penalties.
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
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?
Given the "up in the air" aspects of HIPAA TCS
error reporting, I wonder whether or not the HIPAA transaction
certification engines that are out there today come "out of the box"
configured so that they won't "let through" a transaction
if it's missing a HIPAA-required field that is optional
per X12...given the obvious competence of the folks
who are working the HIPAA effort, and the fact that some of those folks
use the WEDI SNIP testing levels 1-6 model, I'd assume the answer is
that they won't "let through" these transactions...but
we all know the dangers of assuming...perhaps some certification
engines do and some don't...
More relevant to this week's discussion is
the same question applied to transactions managers that generate
997s in response to submitted 837s...Rachel pointed out that
"... the 997 can be kludged to report guide syntax
errors, such as missing mandatory segment or
element..." (Thank you
Rachel!) I wonder if the transactions managers that are being
billed as "HIPAA-ready" currently come kludged (configured?) to do the
appropriate HIPAA-specific mandatory data element error reporting...(I'm
not asking about the inter-segment dependency errors, just the
black-and-white HIPAA-mandated, X12-optional).
Sounds like there won't be a 997 or 824 IG before the
10/16/03 deadline, so what we have today is what we have...And the 997
is what everyone is reading as the standard if they're only looking at
the IGs and addenda, which is all that they're required by law to look
at...
----- Original Message -----
Sent: Friday, April 19, 2002
12:41 PM
Subject: RE: compliance with x12
vs. HIPAA IG
When X12 says an element is optional and HIPAA says it's "Not
Used", that doesn't violate X12 because transmission of the segment
without that element is OK with X12 (because it was optional
anyway). When X12 says the element is optional and HIPAA says
it's "Required", that doesn't violate X12 either because transmission
of the segment with the element always present is OK with X12 (because
optional means you can use it as often as you like...including
always). So what the HIPAA IG is doing is creating restrictions
on X12 that don't violate the original definitions...that's pretty
much how IGs are supposed to work. I think the 997 reporting of
HIPAA usage errors is still up in the air (based on the discussion
that's been going on this week).
Best regards,
Bill Chessman
Peregrine Systems, Inc.
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...
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