Just another contribution to this discussion. While re-reviewing P.L. 104-191 I ran across the following:
P.L. 104-191, August 21, 1996 Subtitle F Administrative Simplification ��PROCESSING PAYMENT TRANSACTIONS BY FINANCIAL INSTITUTIONS ��SEC. 1179. To the extent that an entity is engaged in activities of a financial institution (as defined in section 1101 of the Right to Financial Privacy Act of 1978), or is engaged in authorizing, processing,clearing, settling, billing, transferring, reconciling, or collecting payments, for a financial institution, this part, and any standard adopted under this part, shall not apply to the entity with respect to such activities, including the following: ��(1) The use or disclosure of information by the entity for authorizing, processing, clearing, settling, billing, transferring, reconciling or collecting, a payment for, or related to, health plan premiums or health care, where such payment is made by any means, including a credit, debit, or other payment card, an account, check, or electronic funds transfer. ��(2) The request for, or the use or disclosure of, information by the entity with respect to a payment described in paragraph (1)- ��(A) for transferring receivables; ��(B) for auditing; ��(C) in connection with- ��(i) a customer dispute; or ��(ii) an inquiry from, or to, a customer; ��(D) in a communication to a customer of the entity regarding the customer� s transactions, payment card, account, check, or electronic funds transfer; ��(E) for reporting to consumer reporting agencies; or ��(F) for complying with- ��(i) a civil or criminal subpoena; or ��(ii) a Federal or State law regulating the entity.��. Therefore, until such time as the security rule is adopted in final form, which may or may not contain a requirement for encrypting table 2 data in either the 820 or 835, I believe there is no requirement to encrypt table 2 of either the 820 or 835 when it's included along with table 1 and the entire transactions travels through the banking network. 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
