All I would second what Chris said. From the provider's perspective, DDE systems are not a very good solution - better than paper yes, but a lot of work. It's sort of the electronic equivalent of having to deal with a proprietary form for each payer, at least from the "I gotta handle each payer individually" perspective. Provider like a 'one-stop'shopping' solution to submitting claims, eligibility, etc and receiving RAs and other response transactions.
Jan Root "Christopher J. Feahr, OD" wrote: > Alan, > Thank you for your comment. I think you are absolutely correct about > provider DDE systems (and everything else) eventually morphing into an XML > version of "EDI". Given the huge pent-up desire to implement XML and the > interesting work that OASIS, X12, and others are doing today to create > hybrids of XML and EDI message/transport structures... I think its very > possible that most small providers will never actually see a classic EDI > message inside their offices. So, while I did suggest we "phase them all > out"... I didn't REALLY think that anyone would try to kill DDE with a > law. By the time such a law became enforceable, we'd be ready to migrate > from XML to the "next big thing"! > > My point, however, is that we should not make the mistake of thinking that > DDE systems are very useful to the provider... THEY ARE LABOR-INTENSIVE, > MANUAL SYSTEMS. The "electronic" advantages of DDE are ALL on the payor > end. In the doctor's offices, they still have $20/hr. employees clicking > around on websites with browsers and 33K dialup connections. Doctors' idea > of "automation" is to get a DSL line for the office! HIPAA done entirely > through a DDE interface doesn't improve doctors' live a bit (in my > opinion), but it still allows payors to reduce the sizes of their call > centers and eliminate many data-entry positions. > > Best regards, > -Chris > > At 04:37 PM 5/8/02 -0400, Hirth, Alan wrote: > > > >I don't support the idea of phasing out DDE. Forcing providers off of a > >browser/web based eligibility inquiry, claim status inquiry, and/or claim > >entry system and onto pure EDI is counter productive. Encouraging DDE as a > >supplement to EDI and working to merge the two by developing HIPAA XML seems > >like a better long term strategy. > > > >-----Original Message----- > >From: Christopher J. Feahr, OD > >To: [EMAIL PROTECTED]; [EMAIL PROTECTED] > >Sent: 5/8/02 3:37 PM > >Subject: RE: Data Downloads from DDE Applications > > > >Rachel, > >I would agree with your interpretation of the conventional usage of > >terms > >like "print screen" and "download"... but I do not see clear support in > >the > >law for your definitions. In order to display data on a provider's DDE > >screen, I would argue that the payor is, in fact, "downloading" or > >"transferring" data to the provider's system in a non-standard > >format. There seems to be a need to better define not only the details > >of > >this special type of transfer, but whether there are any restrictions on > > > >what the provider can legally do with the data after it is > >transferred... > >whether it even HAS to wind up on a "screen" or display device... > >whether > >data could be pushed out to a provider's screen under this exception > >without the provider requesting it immediately beforehand, etc. > > > >My suggestion (which, of course, would be pretty difficult to implement) > >is > >that we tighten up the definition of "DDE" systems and then permit them > >to > >be used for another 2 or 3 year transition period... and then phase them > > > >all out! > > > >regards, > >Chris > > > >At 04:04 PM 5/6/02 -0500, Rachel Foerster wrote: > > >Kris, > > > > > >The core difference between a print screen and a file download is just > > >that -- when someone prints a screen no data is being downloaded to the > > > > >local system for additional processing -- the screen (display) is > >intended > > >for a human-to-computer interface. On the other hand, a file download > >is > > >not intended for a human-to-computer interface, but rather, is intended > > > > >for automated processing or a computer-to-computer interface. Just > >because > > >there may be human intervention with a downloaded file, the data in the > > > > >file is intended to be input into another application and not viewable > >"as > > >is" by a human. > > > > > >Therefore, if a file of data is being downloaded, regardless of the > > >transport mode, e.g., HTTP, ftp, or even attached to an email, and the > > >data constitutes one of the covered HIPAA transactions, after either > > >10/16/02 or 10/16/03, the format of the data and the data content must > > >comply with the appropriate HIPAA implementation guide. > > > > > >Rachel > > >-----Original Message----- > > >From: Owens, Kris [mailto:[EMAIL PROTECTED]] > > >Sent: Monday, May 06, 2002 9:06 AM > > >To: '[EMAIL PROTECTED]' > > >Cc: Goulart, Cesar; '[EMAIL PROTECTED]' > > >Subject: RE: Data Downloads from DDE Applications > > > > > >Rachel, > > > > > >Thanks for the response, although it is not what I had hoped to hear. > > > > > >Another thought (yes, I am still trying to justify giving this ability > >to > > >the providers) how would this download be different (in concept) from > >the > > >provider using a print screen option in their operating system? > > > > > >Kris Owens > > >923-8108 > > > > > >"There is no meaning in isolation" > > > > > >-----Original Message----- > > >From: Rachel Foerster [mailto:[EMAIL PROTECTED]] > > >Sent: Saturday, May 04, 2002 1:15 PM > > >To: [EMAIL PROTECTED] > > >Subject: RE: Data Downloads from DDE Applications > > > > > >Kris, > > > > > >My understanding of the DDE exception plus the HHS FAQs on the subject, > > > > >lead me to conclude that the download of the eligibility information > >would > > >be a covered transaction under the electronic transaction final rule, > >and > > >thus, must conform to the 271 specifications. > > > > > >Rachel Foerster > > > > > >-----Original Message----- > > >From: Owens, Kris [mailto:[EMAIL PROTECTED]] > > >Sent: Friday, May 03, 2002 4:12 PM > > >To: [EMAIL PROTECTED] > > >Cc: Goulart, Cesar > > >Subject: Data Downloads from DDE Applications > > > > > >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] > > > > > > > > > > > >--- 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] > > > >Christopher J. Feahr, OD > >http://visiondatastandard.org > >[EMAIL PROTECTED] > >Cell/Pager: 707-529-2268 > > > > > > > >The contents of this e-mail are intended for the named addressee only. It > >contains information that may be confidential. Unless you are the named > >addressee or an authorized designee, you may not copy or use it, or disclose > >it to anyone else. If you received it in error please notify us immediately > >and then destroy it. > > Christopher J. Feahr, OD > http://visiondatastandard.org > [EMAIL PROTECTED] > Cell/Pager: 707-529-2268
