If you accept the data but later reject the claim within your adjudication system for business reasons you would still be in compliance, you do not have to change the way you do business edits as long as they are done after you've excepted the transaction into your system.
Mike Winston Business Systems Analyst Trigon ISD Ph (804) 354-4521 Fx (804) 678-0452 [EMAIL PROTECTED] This message, including files attached to it, may contain confidential information that is intended only for the use of the ADDRESSEE(S) named above. If you are not the intended recipient, you are hereby notified that any dissemination or copying of the information is strictly prohibited. If you have received this message in error, please notify the sender immediately and delete the message from your system. Thank you. > -----Original Message----- > From: Heiert, David [SMTP:[EMAIL PROTECTED]] > Sent: Wednesday, April 24, 2002 5:08 PM > To: '[EMAIL PROTECTED]'; [EMAIL PROTECTED] > Subject: RE: Compliance with x12 vs. HIPAA IG > > 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.. > > -----Original Message----- > From: Rachel Foerster [mailto:[EMAIL PROTECTED]] > Sent: Wednesday, April 24, 2002 5:03 PM > To: [EMAIL PROTECTED] > Subject: RE: Compliance with x12 vs. HIPAA IG > > > 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/> > > -----Original Message----- > From: Barton, Joe [mailto:[EMAIL PROTECTED]] > Sent: Tuesday, April 23, 2002 6:16 PM > To: '[EMAIL PROTECTED]' > Subject: RE: Compliance with x12 vs. HIPAA IG > > > 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 > > -----Original Message----- > From: Rachel Foerster [mailto:[EMAIL PROTECTED]] > Sent: Friday, April 19, 2002 7:30 PM > To: [EMAIL PROTECTED] > Subject: RE: Compliance with x12 vs. HIPAA IG > > > > > 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/> > > -----Original Message----- > From: Barton, Joe [mailto:[EMAIL PROTECTED]] > Sent: Friday, April 19, 2002 4:30 PM > To: '[EMAIL PROTECTED]' > 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? > > -----Original Message----- > From: Cynthia Korman > [mailto:[EMAIL PROTECTED]] > Sent: Friday, April 19, 2002 2:18 PM > To: [EMAIL PROTECTED] > Subject: Compliance with x12 vs. HIPAA IG > > > > > 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... > > Cynthia Korman, Principal > Strategic System Solutions, LLC > 973 394-9529 > [EMAIL PROTECTED] > <mailto:[EMAIL PROTECTED]> > www.healthcare-systems.com > <http://www.healthcare-systems.com> > > > ----- Original Message ----- > From: Bill Chessman > <mailto:[EMAIL PROTECTED]> > To: '[EMAIL PROTECTED]' > <mailto:'[EMAIL PROTECTED]'> > 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. > > -----Original Message----- > From: Cynthia Korman > [mailto:[EMAIL PROTECTED]] > Sent: Friday, April 19, 2002 9:11 AM > To: [EMAIL PROTECTED] > Subject: compliance with x12 vs. HIPAA IG > > > > > 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] > <mailto:[EMAIL PROTECTED]> > www.healthcare-systems.com > <http://www.healthcare-systems.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. > > > > > ********************************************************************** > 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. >
