It's extremely important to read the actual language of the Electronic Transaction Final Rule to understand what's required, and what's permitted under what conditions.
For many of the transactions, the final rule is quite explicit in identifying what entity type the transaction is originating from and to what entity type it's destined. For other transactions, no such specificity exists, or the rule says that the transaction is from any entity to a health plan. The DDE exception is just that -- an exception -- for the **provider** to a health plan. Under the DDE exception the format requirements are removed, but the data content requirements remain. The DDE exception is not concerned with whether the DDE mechanism is the old CICS, web browser, or what. But, what the HHS FAQs clearly indicate, is that neither fax or IVR is either considered a DDE exception or an electronic transaction. Thus both of these message exchange modes are not covered under the electronic transaction final rule. 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: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] Sent: Thursday, May 02, 2002 5:33 PM To: [EMAIL PROTECTED] Subject: RE: Voice Response Systems 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] > > > >
