I would have a hard time describing what I think is legal or illegal in
a companion guide.  I could better tell if I saw a few examples.  But
like Justice Potter Stewart said when he admitted he couldn't really
describe obscenity, "I know it when I see it..."

Most, if not all, of the situational notes I've seen in the HIPAA IGs
seem to have their required uses specified -  so the sender should know
ahead of time what to stick in such elements or when to use such
segments. For example, it's not up to the payer to dictate when the
situational middle name should be sent - instead, the provider sends it
if he has it;  in effect, it's up to the sender's discretion.

I think most anything that smacks of IG-type language in a companion
guide is illegal.  As an example, I think it's okay for you, as a payer,
to say that you will process up to four diagnosis codes per claim;
that's a subtle (or not so subtle) difference from saying HI05 through
HI08 may not be used.

My concern, as always, is for the poor provider:  trading partner
specific stuff could end up requiring him to need more than one map for
any particular transaction set or function.

William J. Kammerer
Novannet, LLC.
Columbus, US-OH 43221-3859
+1 (614) 487-0320

----- Original Message -----
From: "Rachel Foerster" <[EMAIL PROTECTED]>
To: <[EMAIL PROTECTED]>
Sent: Wednesday, 17 July, 2002 03:20 PM
Subject: RE: Testing for levels 3, 4, and 6

Of course trading partner specific stuff is legal....this is where much
of the situational items are defined. The only prohibition is that any
trading partner specific stuff not violate any of the HIPAA
specifications.

It's the trading partner specific stuff (most often from the payer) that
results in companion documents which give guidance to the providers such
that when they submit a HIPAA compliant claim it can pass through the
payer's adjudication system as cleanly as possible. After all, the goal
is not to send a HIPAA complaint claim, the goal is to get paid!

Rachel
Rachel Foerster
Principal
Rachel Foerster & Associates, Ltd.
Professionals in EDI & Electronic Commerce
39432 North Avenue
Beach Park, IL 60099
Phone: 847-872-8070
Fax: 847-872-6860
http://www.rfa-edi.com


-----Original Message-----
From: William J. Kammerer [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, July 16, 2002 9:07 PM
To: [EMAIL PROTECTED]
Subject: Re: Testing for levels 3, 4, and 6


Chris:

Can we take this discussion to one or the other of the WEDI/SNIP mailing
lists, in order to avoid cross-posting?  I suggest "Transactions,"
simply because discussion may uncover bigger issues than simply testing.

Having said that, I'm sure the various purveyors of HIPAA validation
tools and services must have the HIPAA IGs in some machine readable
format, replete with business rules and access to standard code sets.
Otherwise, they wouldn't be able to do HIPAA compliance testing (unless
they had really lousy programmers who hard coded everything in their
application code!!). So the stuff (machine readable IGs) obviously
exists - though the vendors may treat these materials as valuable
intellectual property, considering a lot of business knowledge is tied
up in them. And once an IG has been codified in some interoperable
standard, like SEF, it is not rocket science to produce an IMPDEF
version (or vice versa).

But I really want to know just what the heck anyone else (besides
testing or translator vendors) would want with machine readable HIPAA
IGs?  Why would a payer or provider want to promulgate her own "subsets"
of the HIPAA IGs?  What kind of trading partner specific junk would you
expect to see in one of these?  Is trading-partner specific stuff even
legal under HIPAA?

William J. Kammerer
Novannet, LLC.
Columbus, US-OH 43221-3859
+1 (614) 487-0320





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