Would anyone here have an opinion of "what type of entity", from a
HIPAA Transaction Rule perspective, the following operation could be
categorized?
I have an operation that receives; on behalf of a HEALTH PLAN, paper claims
from the PLAN's health care PROVIDERS (doctors, hospitals, etc.).
We then take the paper claims; scan them into an imaging system, key the
claims into our own claims processing software system (off the scanned image
of the paper claim), adjudicate the claim, cut the paper check and EOB
and/or ERA and mail.
The submitting providers; and the payee's on the backend have no knowledge
of us. The checks bear the logo/address/signature of our health plan
clients.
And the address where the paper claims are mailed have the name of our
health plan clients; with a PO Box that we set up; and from which we collect
the inbound mail.
Question: does this make us a "CLEARINGHOUSE"? [I had, naively perhaps,
assumed that a "HIPAA defined clearinghouse" was one that reformatted data
from a non-HIPAA standard format to a HIPAA standard format or vice-versa;
and I had assumed that the media on both sides of this are electronic - but,
when I look at the definition below; perhaps the rule applies to "paper" as
a 'non-HIPAA standard format' as well.].
Definition below for convenience - from the WEDI/SNIP Glossary
Health Care Clearinghouse: Under HIPAA, this is an entity that processes or
facilitates the processing of information received from another entity in a
nonstandard format or containing nonstandard data content into standard data
elements or a standard transaction, or that receives a standard transaction
from another entity and processes or facilitates the processing of that
information into nonstandard format or nonstandard data content for a
receiving entity. Also see Part II, 45 CFR 160.103.
Henry A Perretta
HAPCO International, LLC
6302 Dunman Way
Alexandria,VA, 22315
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