David, Thank you for your comments/suggestions. With vision care's primary HIPAA-EDI focus for the moment on "inadequate codeset" issues, we have probably acquired a slightly different view of the kind of provider input that we would like to see "more of". Nevertheless, I think it's important to consider some of the separate missions that would be served by bringing the provider community closer to the "HIPAA/standards community". Here are some that come to mind:
1. General education about the Transaction Rule and EDI (financial benefits of EDI, the role of DDE, what a CH can/cannot do, etc.) 2. General education about the Privacy and Security Rules' impact on provider information management systems 3. Patient Medical Record Information (What PMRI data elements are being considered in each healthcare domain; are they adequate? Who/where are the workgroups looking at PMRI requirements for specialty areas? How would an individual provider follow this work or see periodic summaries of work in progress?) 4. Medical information codesets. (Who are the owners of existing codesets; where/how do providers recommend changes, additional codes, etc.? How do PMS vendors keep provider systems synchronized with HIPAA-standard codesets?) 5. Providers' messaging requirements (What are various types of PMRI-related messages routinely encountered in each specialized healthcare domain.. provider-to-provider, provider-to-patient; provider-to-research facilities like CDC, FDA, etc.?) WEDI (both nationally and regionally) in partnership with existing provider associations would seem to be an excellent approach to the basic HIPAA continuing education needs (# 1 and 2). Items 3-5 are mainly concerned with obtaining provider feedback (from the "front lines"), but a certain amount of basic technical education will improve the quality of that feedback. I believe that many doctors are actively thinking about these issues, but do not know where the relevant discussions are taking place, what has already been discussed, etc. There is also likely to be some conceptual fuzziness about basic "medical informatics" issues. Perhaps HL7 would be the appropriate lead-organization for items 3-5. Best regards, -Chris At 09:26 AM 5/29/02 -0400, David Kibbe wrote: >"urn:schemas-microsoft-com:office:office" xmlns:w = >"urn:schemas-microsoft-com:office:word"> >Dear Mark, Tami, and others: I'd like to weigh in here briefly on WEDI's >involvement with providers, especially physicians. I am the new Director, >Health Information Technology, for the American Academy of Family >Physicians, AAFP, the home base for 93,000+ family doctors in this >country. I was hired by the Academy, in part, because the leadership and >membership of the Academy understand how important HIPAA has become to >family medicine practices. One our of every four outpatient visits is >with a family doctor: that's a whole lot of transactions! One of my first >recommendation to the Academy was that we re-join WEDI, and this has just >occurred. > >I believe physicians in this country are willing to become a lot more >involved in the HIPAA implementation. After all, they are intelligent >people who care deeply about running their practices better. But WEDI and >other major groups need to understand that the most important pathway to >that involvement is through the physicians' specialty organizations, like >the AAFP, the AAP (American Academy of Pediatricians), ACP (American >College of Physicians -- the internist's group) and others. There are >over 240,000 medical practices in the US, and over half of them are staff >by physicians who belong to those three organizations alone. Getting to >each of these practices individually in conferences, etc., is not going to >happen. > >The reason this is so important is a matter of trust. Physicians >generally trust their own specialty organizations, and look to them for >accurate and timely information on a whole range of issues, from practice >management to continuing medical education. > >The problem is that many of the specialty organizations in medicine lack >technical expertise, and many of their staff members don't understand the >importance nor the details of the HIPAA standards. I think there are >still many leaders in these physician membership organizations who both >don't understand the potential benefits of HIPAA to their members' >practices, and also think that HIPAA may go away. Probably a majority of >the leaders in these organizations don't know what WEDI is or the role >WEDI has to play in the HIPAA-EDI implementation. Finally, the whole >topic of EDI is foreign to many of the staffers in these organizations. > >Therefore, I want to promote the idea of a WEDI-sponsored forum, to which >leaders and staffers from America's specialty organizations are invited to >themselves be educated and made aware of HIPAA basics. If you invite >them, they will come, because they are starting to hear more and more >requests for information from their members. And if they come, they will >go back to their organizational headquarters with a much richer >understanding of the magnitude of the HIPAA implementation, and a >committment to assist all of us work towards a smooth and non-cataclysmic >transition...something we all want. > >Those of you who've been in WEDI much longer than I have, please toss this >idea around and let me know what you think. I know for certain that we >will not attain an educated and prepared medical practice industry if we >continue to address the issues one practice at a time, or through local >workshops, etc. > >Thanks for your attention to this idea. > >DCK > >David C. Kibbe, MD >Director, Health Information Technology >American Academy of Family Physicians > >Pres-elect, NCHICA >Chapel Hill, NC > >800-757-1354 > > >-----Original Message----- >From: sharon cox [mailto:[EMAIL PROTECTED]] >Sent: Tuesday, May 28, 2002 3:58 PM >To: [EMAIL PROTECTED] >Cc: [EMAIL PROTECTED] >Subject: RE: provider involvement > >Mark, >Your information is very valuable. We are currently addressing questions >from many of our providers and frequently send them to your site. Many are >asking a question that we cannot currently answer. They want to know which >payors are implementing the October 2002 cutoff date instead of the >October 2003 cut off dates. We are stressing that they file extensions, >but they feel this paper will not help them when a payor is saying they >will enforce an October 2002 date. What are your thoughts on this? Can you >direct me to a list of each payor s proposed cut off date? > >Any help would be appreciated. > >Sharon L. Cox >VitalWorks - Product Manager, Office-Based Division >1-205-981-5605 >[EMAIL PROTECTED] > >-----Original Message----- >From: McLaughlin, Mark (DBQ) [mailto:[EMAIL PROTECTED]] >Sent: Wednesday, May 22, 2002 3:44 PM >To: '[EMAIL PROTECTED]'; [EMAIL PROTECTED] >Subject: RE: provider involvement > >Tami, that type of exposure is tremendous and exactly what the industry >needs to happen. Speaking strictly from a WEDI SNIP Transactions Workgroup >Co-chair standpoint we would love to have more provider involvement in all >of our sub workgroups. Anyone interested in joining in on the discussions >is more than welcome to do so through the SNIP web site at ><http://snip.wedi.org>http://snip.wedi.org. Go to the Workgroups and >Listservs portion of the site. Interested parties may join any of the >listservs and/or workgroups we have today. Conference calls are also >listed under this section. >Having said that, I think there is a general concern throughout the >industry than many of the small providers are missing the messages given >through the many industry and government meetings and conferences. I would >also recommend that you direct them to the WEDI web site at www.wedi.org >to check out upcoming conferences under the Events tab. Typically there >are events in different parts of the country so travel concerns are easier >to deal with. Additionally, the CMS web site is a good source of >information for past, present, and future announcements. You can direct >them to a lot of good information by sending them to ><http://aspe.os.dhhs.gov/admnsimp/>http://aspe.os.dhhs.gov/admnsimp/ >I hope this helps get them started. > > > Mark > > > > Mark McLaughlin > > Regulatory Policy Analyst > > McKesson > > 700 Locust St. Suite 500 > > Mail stop IADU-7 > > Dubuque, IA 52001 > > (563) 557-3654 phone > > (563) 557-3334 fax > > [EMAIL PROTECTED] > > Confidentiality Notice: This e-mail message, including any attachments, > is for the sole use of the intended recipient(s) and may contain > confidential and privileged information. Any unauthorized review, use, > disclosure or distribution is prohibited. If you are not the intended > recipient, please contact the sender by reply e-mail and destroy all > copies of the original message. > > > >-----Original Message----- >From: [EMAIL PROTECTED] >[<mailto:[EMAIL PROTECTED]>mailto:[EMAIL PROTECTED]] >Sent: Wednesday, May 22, 2002 3:28 PM >To: [EMAIL PROTECTED] >Subject: provider involvement > > >Last week there were some emails regarding a lack of provider involvement >so I took the concerns about lack of provider (non retail pharmacy) >involvement to our billing office management (we have a central billing >office for 4 hospitals). They have offered to bring the issue of WEDI SNIP >involvement to our state AAHAM and Maryland Hospital Association >memberships. > >What groups would you like more input in? Are there conference call >schedules available? Are there meetings or conferences that they should >plan to attend? > >Please let me know so we can help to get the word out. > > >Tami Leaver >Sr. Application Analyst >Medstar Information Systems > >410-933-6905 >email: [EMAIL PROTECTED] > > > > > Jan > Root > > <janroot%uhin.com@interne To: > [EMAIL PROTECTED] > t.mhg.edu> cc: > > Subject: Re: Data > Downloads from DDE Applications > 05/13/02 10:11 > AM > > > > > > >Chris >I too worry about under-representation of providers in the various >non-retail >pharmacy SDOs. I think that NCVHS is working on a standard for medical >records.... >I can't recall if it's just for computerized/electronic medical records or >all >medical records.....? Kepa? Can you give us an update? Is that an >appropriate >thing to talk about on this list serve? > >Jan Root > >"Christopher J. Feahr, OD" wrote: > > > Thanks, Jan! While this seems obvious, I've had payors react with > > disbelief and surprise when I make this assertion. But the other, >perhaps > > more malignant, aspect of this is that providers don't seem to be upset > > either! A very small # of them are aware of the labor-intensive aspect >of > > this and are "doing the math", but most just seem to regard DDE as a >small > > but positive step in the direction of automation. In net-$, however, it > > can be a step backwards... at best it's probably a lateral move. DDE > > systems will disappear overnight when doctors (and hospitals) stop using > > them and lean on their software vendors to provide real EDI solutions. > > > > This is one more reason to think about creating a national, > > provider-oriented SDO (for all non-retail-pharmacy providers). I can >hear > > the collective groan, but wait a second! This would not REQUIRE any > > attendance by members of the payor or CH industry. Representatives from a > > monolithic provider-SDO could, however, attend all the current DSMO > > meetings in sufficient numbers to populate any workgroup that even >remotely > > impacted providers. The vision industry has finally (this week, > > actually) acknowledged the need for an internal industry organizational > > structure for modeling/articulating our special data requirements for > > eyewear claims... and THAT organization (we still don't know what to call > > it) will be able to speak with a single voice to HL7 and X12 about HIPAA > > messaging standards...as well as to our manufacturers' association about > > related supply-chain transaction standards. > > > > The more I think about this, however, the more I believe that a parallel > > effort should be underway to represent ALL doctors, hospitals, labs, and > > DME providers. Virtually all types of providers have a need to share > > information amongst themselves and to aggregate information about >TREATMENT > > across the healthcare industry. So while we would all benefit from > > standard medical record structures, etc., I don't think we want 15 > > different provider groups "standardizing" medical record formats > > individually. I'm not even sure which existing SDOs would want to tackle > > national EMR standardization. Does anyone know who might be working on >EMR > > standards now? > > > > Something else to think about... (like we don't have enough!) > > -Chris > > > > At 10:28 AM 5/10/02 -0600, Jan Root wrote: > > >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]>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]>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]>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] > > Christopher J. Feahr, OD http://visiondatastandard.org [EMAIL PROTECTED] Cell/Pager: 707-529-2268
