Ok, so in reading these two sections, does that mean HTML still must
conform?  If the format is XML, playing semantics, would it be exempt
because it is not expressly identified?  What about a closed system where
the data is NOT for billing purposes at all?

I'm in the process of spec'ing a system for a New England Public Health
Department that would be impacted by this.  Of course, privacy and security
are being built-in, however, since it is a closed system, not transactional
considerations were given thus far.

TMc

-----Original Message-----
From: Mosesso, Laura [mailto:[EMAIL PROTECTED]]
Sent: Thursday, May 02, 2002 4:53 PM
To: [EMAIL PROTECTED]
Subject: TCS: Voice Response Systems


> I am in search of clarification regarding Voice Response System
> requirements under the TCS rule.
>
> Page 50315 of the 8/17/00 Federal Registrar states that telephone voice
> response [systems] must conform to the data content portion of the
> standard, but not the format.
>
>       "Certain technologies present a special case for the use of standard
> transactions. We proposed that telephone voice response, ''faxback'', and
> Hyper Text Markup Language (HTML) interactions would not be required to
> follow the standard. We have since reevaluated this position in light of
> the many comments on this position and on developments in the EDI industry
> which continue to expand the options in this area. We have decided that,
> instead of creating an exception for these transmissions, we will
> recognize that there are certain transmission modes in which use of the
> format portion of the standard is inappropriate. However, the transaction
> must conform to the data content portion of the standard."
>
> But a 12/28/00 DHHS FAQ response states:
>       "Fax imaging and voice response transmissions are not subject to the
> HIPAA transactions standards but may have to meet privacy and security
> standards. Health plans may continue to offer these services, however,
> they must still be able to accept and send the HIPAA standard
> transactions."
> And the Medicare Managed Care FAQ's posted 3/26/02 states:
>       "Voice response or fax systems do not have to meet the data content
> requirements of the HIPAA standard."
>
> Can someone help clarify this seemingly conflicting information?
>
> Your feedback is appreciated.
>
> Laura A. Mosesso
> Coventry Health Care
> HIPAA/EDI Compliance Manager
> Email:  [EMAIL PROTECTED]
>
>
>
>

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