We have a web application for our healthplan that supplies eligibility and claims status information to providers. Once a provider has displayed the information, they have an option to "download" the information to their PC. My question - should we consider the download to be a covered transaction?
I find the following in the regulations:
160.103 Transaction means the exchange of information between two parties to carry out financial or administrative activities related to health care.
162.923 (a) General rule. Except as otherwise provided in this part, if a covered entity conducts with another covered entity (or within the same covered entity), using electronic media, a transaction of which the Secretary has adopted a standard under this part, the covered entity must conduct the transaction as a standard transaction.
(b) Exception for Direct data entry transactions. A health care provider electing to use direct data entry offered by a health plan to conduct a transaction for which a standard has been adopted under this part must use the applicable data content and data condition requirements of the standard when conducting the transaction. The health care provider is not required to use the format requirements of the standard.
162.1201 Eligibility for a health plan transaction (a) An inquiry from a health care provider to a health plan, or from one health plan to another health plan to obtain...(1) Eligibility to receive health care under the health plan. (2) Coverage of health care under the health plan. (3) Benefits associated with the benefit plan. (b) A response from a health plan to a health care provider's (or another health plan's ) inquiry described in the paragraph(a) of this section.
162.1402 Health care claims status transaction. (a) An inquiry to determine the status of a health care claim. (b) A response about the status of a health care claim.
OK, so I read all this and it would seem that the downloads are to carry out administrative activities, and they are eligibility responses, or claims status responses. My only hope is that the web application has already done the request and response and that this is somehow after the fact, and therefore not covered... or perhaps the fact that this is from a DDE application gets us by the format requirements. If these are in fact a covered transaction they become useless because the providers that are utilizing these are doing so because they have no technical facility to handle an X-12 format.
Any thoughts?
Kris Owens
Senior IS Project Manager - HIPAA Project
Presbyterian Healthcare Services
Albuquerque, NM
505.923.8108
[EMAIL PROTECTED]
"There is no meaning in isolation"
--- PRESBYTERIAN HEALTHCARE SERVICES DISCLAIMER ---
This message originates from Presbyterian Healthcare Services or one of its affiliated organizations. It contains information, which may be confidential or privileged, and is intended only for the individual or entity named above. It is prohibited for anyone else to disclose, copy, distribute or use the contents of this message. All personal messages express views solely of the sender, which are not to be attributed to Presbyterian Healthcare Services or any of its affiliated organizations, and may not be distributed without this disclaimer. If you received this message in error, please notify us immediately at [EMAIL PROTECTED]
