I have been patiently reading the listserve items about this issue before weighing in. I agree with what Rachel has been saying about the interpretation of the Situational versus Not Used items. That is always how I have understood the HIPAA regulations. Because of that through the work of the Public Health Data Standards Consortium and the National Association of Health Data Organizations (NAHDO), the Health Care Service Data Reporting guide (X156) was approved for development by X12N. That guide is an 837 implementation guide being designed to use the 837 standard to report what I like to call "what's-wrong-with-you and how-much-does-it-cost" data to agencies with authorizing legislation as at least one set of users. For instance in the Institutional Claim guide (X096 or X141-Addenda Guide), the DMG segment for reporting Race and Ethnicity is listed at NOT USED. Those data elements are critical to most state discharge data reporting systems. In the X156 guide they are listed as SITUATIONAL to allow for the reporting of that information. The X156 implementation guide is being written as an alternative to use the 837 standard rather than force even more proprietary formats to be supported by the provider community to comply with what is typically state or federal law for reportable information.
With that said, I would like to go on record to say that writing the X156 implementation guide is my second best option for fulling these required reporting needs. The best solution in my view is what we have now in NYS with the UB-92 flat file. The agreement we have with providers and payers in NYS is that if there is a field or record type that is not needed by a payer or state agency then that field is IGNORED, BUT NOT REJECTED. What that means is that we do not need a separate implementation guide to use the same standard to report state mandated data to the state agency and to use for billing institutional services. The langauge in HIPAA make this mulitiple use of the 837 transaction impossible. The X156 guide is being written because the 837 standard is the appropriate standard to choose for these reporting requirements, since the data source is typically bound by HIPAA and must use that standard for their institutional billing. The X096/X141 guide named under HIPAA would not be sufficient to satisfy these mandated reporting needs and still be compliant under HIPAA. If given a chance to vote again, I would vote that the IGNORE, DON't REJECT axiom be built into HIPAA, but since that is not the case it is all ahead full steam with the development of the X156 guide for reporting health care services. Bob Davis
