Exactly my point.  On top of that, the vendor is not a covered entity and 
therefore cannot be "compliant".  It is the provider that is a covered entity 
and must be compliant.  And if the provider has filed for ASCA, it is the 
provider that has committed to the Secretary, in the ASCA filing, to have a 
test plan that begins no later than April 15 2003.  I would expect the test 
plan to be something more substantial than "I trust the vendor will have a 
good product that I will not need to test."

The best the vendor can do is to provide a "platform for compliance" for the 
provider to use.  If the platform has been tested under lab conditions and 
proven to be compliant, the provider stands some chance of being compliant at 
some point.  If the platform has not been tested for compliance, the provider 
will have a lot of work to do, and all bets are off.

In fact, if I was the vendor, I would start thinking how I am going to help my 
clients test their compliance.  It is a business opportunity to have a lot of 
very happy customers.

Kepa




On Monday 25 November 2002 07:27 pm, Julie Thompson wrote:
> While a good idea, similar to Claredi's certifcation model, the reality is 
> that most implementations are customized due to state regulatory 
> requirements+++.
> 
> Therefore a software vendor should and could call themselves "HIPAA 
> compliant", but each covered entitiy is responsible for their own compliance 
> and must test independently.
> 
> Sorry, guys :=(
> 
> Julie A. Thompson
> V.P. Concio
> 
> 
> 
> 
> 
> 
> From: Kepa Zubeldia <[EMAIL PROTECTED]>
> Reply-To: "WEDI SNIP Testing Subworkgroup List" 
> <[EMAIL PROTECTED]>
> To: "WEDI SNIP Testing Subworkgroup List" <[EMAIL PROTECTED]>
> Subject: Re: New Issue from Issues Database
> Date: Mon, 25 Nov 2002 16:06:06 -0700
> 
> John,
> 
> Has this been discussed yet?  Did this vendor file for the ASCA extension?
> Very interesting topic.
> 
> Kepa
> 
> 
> 
> On Thursday 14 November 2002 07:20 am, [EMAIL PROTECTED] wrote:
>  > Hello everyone,
>  >
>  > This issue was recently added to the Issues Database and was assigned to
>  > our SWG.  Please take a few minutes and review the issue. We can discuss
>  > this in our conference call today.  Thanks!!
>  >
>  >  Issue
>  >
>  >    ASCA requires that compliance testing be preformed no later than Arpil
>  >    2003. I work for a software vendor who will supply the 4010 837 to
>  >    hundreds of customer throughout the US. For testing purposes, may we,
>  >    the software vendor, test on behalf of our customers? If so, would we 
> be
>  >    required to use each individual customer's data? Or, must each of our
>  >    customers perform their own testing? If there are any more detailed
>  >    rules, i.e., internal vs external testing, on this same topic, I would
>  >    appreciate an explanation of the detailed rules as well. Thank-you
>  >
>  > _______________________________________________
>  >
>  > John Lilleston
>  > Technical Supervisor
>  > Verizon Information Technologies, Inc.
>  > Healthcare Solutions
>  > 813-979-3225
>  > [EMAIL PROTECTED]
>  > http://www.VerizonIT.com/
>  > _______________________________________________
> 
> 
> ---
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