Janie,

Are you talking about a HIPAA "companion document", or about a "transitional 
document" for implementation today?

For example, a lot of payers today still require the "Type of Service" in 
order to adjudicate the claim.  I have seen documentation from payers and 
clearinghouses instructing the providers to send the TOS, even though the 
HIPAA guides say it is "not used".

This is a transition issue.  In effect, they are creating a proprietary 
transaction based on the HIPAA guides, but it is not a HIPAA transaction per 
s�.  Sort of like having training wheels when you are learning to ride a 
bike.  Is it a bike or a tricycle?

The fact is that some of these transition issues will not be resolved until we 
get very close to the 10/16/03 deadline.  By then all of these transition 
issues will have to be resolved.

In the meantime, and as long as both trading partners agree to these 
additional requirements in order to both get their feet wet with HIPAA 
transactions AND still get paid for those claims, it is OK.  But both parties 
must understand that these are not valid HIPAA "companion documents" at all, 
but a transitional implementation.  For sure the GS08 should NOT have the 
HIPAA standard designator of 004010X098 but something else, so nobody gets 
confused.

Have you seen the "HIPAA Helpful Hints" documents?  They were released without 
fanfare on July 1st at //www.hipaa.org/hints/  The transition issues, among 
other, are addressed there.

This is a very touchy subject.  Some people "need" training wheels before they 
can learn to ride a bike.  Other people consider that training wheels will 
make it more difficult to learn to ride a bike and will slow the process.  
Other people want to get from here to there and don't care whether they learn 
to ride the bike or not, that is not their goal.

Having said all that... if they really intended to modify the HIPAA 
requirements by "requiring" something that is not used in the HIPAA guides 
even after 10/16/03, I am sure you can point to the Final Rule on 
transactions where it says that you cannot do that.

Kepa



On Thursday 11 July 2002 02:01 pm, Janie Miller wrote:
> Probably ignorant questions, but I must clarify for my own sanity:
> 
> In a companion document, is it HIPAA compliant for a covered entity to
> "require" certain "situational" loops/segments/data elements of its trading
> partner(s)?  What about when the covered entity wants to "require" certain
> specific data in "NOT USED" description fields?


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