May I suggest using RFC2119 at www.ietf.org/rfc/rfc2119.txt for choice of words like MUST, SHOULD, MAY, etc.
Ajay Ajay K Sanghi Managing Director ABO Software Private Limited B102 Gulmohar Park, New Delhi 110049 Tel: +91 11 6968976, 6512822 Fax: 6518873 Website: http://www.abosoftware.com email: [EMAIL PROTECTED] -----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]]On Behalf Of Larry Watkins Sent: Thursday, April 25, 2002 5:35 PM To: [EMAIL PROTECTED] Subject: RE: Compliance with x12 vs. HIPAA IG Rachel, et al -- Although the following from Rachel accurately describes the intention of HHS and X12 in creating these Implementation Guides, it does not appear to me to be the direction we are headed for compliance. At the last X12 meeting, the Architecture Task Group (TG8) was asked to review the Guides for language that says one "should" use or not use an element vs. "must" use or not use an element. For example, when the IG's describe "Situational" elements, it says they "should" not be used when the situation does not apply. The X12N TG8 position can be found at this site: http://www.x12.org/x12org/subcommittees/X12N/N0800_Opinion_Data_Element.PD. In short, the TG8 recommendation is that "should" is not as strong as "must", and so unless there is a clear mandate, the Guides do not require implementers to do what the Guides say they "should" do. Note that this is NOT the position of X12N, but only the TG8 recommendation. We will take up this issue again at the upcoming X12 meeting in June in Minneapolis. Claredi has taken the initiative and created "relaxed" edits that take this new interpretation into account. In short, the relaxed edits make it much easier to create a HIPAA compliant transaction. Many feel this approach is more appropriate for an industry in flux to an entirely new standard. Others believe that if we don't make the rules clear and consistent now, we never will. Claredi has made this option available to help the industry in making a decision about what is best for HIPAA implementation. Should make for interesting discussion at X12 and elsewhere. Finally, it is my view that HHS makes the ultimate determination here. X12N can take a position on what the Implementation Guides say or mean, but only HHS can tell us what is compliant and what is not. To date, HHS has indicated the position Rachel describes in the message following this one. We'll see if that changes after June. Hope this helps, Larry Watkins Co-Chair, ASC X12N Health Care Task Group Vice President & COO, Claredi Corporation Office: (801) 444-0339 x204 Fax: (770) 419-5295 Mobile: (770) 331-1898 e-Mail: [EMAIL PROTECTED] -----Original Message----- From: Rachel Foerster [mailto:[EMAIL PROTECTED]] Sent: Wednesday, April 24, 2002 5:23 PM To: [EMAIL PROTECTED] Subject: RE: Compliance with x12 vs. HIPAA IG Under the HIPAA IG's there are NO optional elements, codes, segments or loops. All constructs are either required, not used, or situational. If the construct is marked situational, the description of the situation must be evaluated to determine the truth of the situation when applied to you. If the situation is true for you, then the situational construct becomes required, if not true, then it's not used. If some cases, the truth of the situation is determined not by the originator of the transaction, but by the intended receiver of the transaction. 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: Heiert, David [mailto:[EMAIL PROTECTED]] Sent: Wednesday, April 24, 2002 11:12 AM To: 'David Frenkel'; [EMAIL PROTECTED] Subject: RE: Compliance with x12 vs. HIPAA IG My thought would be that any item that was truly optional but was included cannot cause the receiver to reject the massage... In reality, I would think that as long as the message included the data necessary to process the claim or whatever it may be AND it is formatted correctly, the system would proceed as if the extraneous items were not there... I mean if someone owes you 2 dollars and gives you 5, did they pay back the 2 dollars? I think the answer is yes.... -----Original Message----- From: David Frenkel [mailto:[EMAIL PROTECTED]] Sent: Wednesday, April 24, 2002 11:52 AM To: [EMAIL PROTECTED] Subject: RE: Compliance with x12 vs. HIPAA IG Joe, The letter of the law says the transaction must be HIPAA compliant or it is rejected. I would think you would have to use some judgement though. If you get a lot of claims that have �extraneous� information you might process them and follow-up with the provider as time allows. If you are like most state agencies you might not have the resources to reject a lot of claims and subsequent phone calls. I worked for another State HHS and we came under political pressure to get claims paid on a timely basis before there were prompt pay laws. I imagine you have the same issues. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 425-260-5030 -----Original Message----- From: Barton, Joe [mailto:[EMAIL PROTECTED]] Sent: Tuesday, April 23, 2002 4:16 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] www.healthcare-systems.com ----- Original Message ----- From: Bill Chessman To: '[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] 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/. 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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.
