All this talk about the HIPAA IG and X12 Compliance and 997 vs 824 vs something completely different has my head spinning a little bit. Another thing that was mentioned made me wonder about how the state laws may fit into this jigsaw puzzle called HIPAA Compliance.
In trying to keep my volume of e-mail archives to a minimum, I confess I've lost the name of the person who posted the remark, but it went something like, "what about state-level mandates for specific data used for statistical analysis, epidemiological tracking, etc. and how does that affect segments which are deemed in the HIPAA IGs as NOT USED?" Is there any precedent for putting state laws on top of federal laws? By that I don't mean as an attempt to supersede, but rather as an attempt to augment. If the state says, "we want to do everything that's called for in HIPAA but there's also this other stuff we want in addition"...would that be possible? legal? on the horizon? Also, if so, would we likely expect some states to issue their own "HIPAA++" IGs? Is this something that might need to be taken into consideration? Also, what happens if the claim is across state lines and both have their own HIPAA++ requirements (scenario 1: they kind of overlap, scenario 2: they conflict)? Just thinking "aloud." Best regards, Bill Chessman Peregrine Systems, Inc.
