Great discussion by all!  

It's a credit to vendors and covered entities alike for the efforts to
define "certification".  It just happens that vendors have traveled down
the path first, which gives us all a good starting point on the road to
defining "certification" for all of us.  Vendors just need to be
cautious about giving the perception of advertising. Debate on!!

Darcy Otis
SimplicEDI

-----Original Message-----
From: Huber, Cheri [mailto:[EMAIL PROTECTED]] 
Sent: Tuesday, November 26, 2002 11:35 AM
To: WEDI SNIP Testing Subworkgroup List
Cc: '[EMAIL PROTECTED]'
Subject: RE: HIPAA Certification & Conformance Rules

I encourage everyone to take a look at the website for the HIPAA
Conformance
Certification Organization (HCCO) at www.hcco.us.  You will see that
this
new organization has undertaken the monumental task that you describe,
Rachel - defining the criteria by which conformance with HIPAA may be
measured and certified.  It is HCCO's mission to establish such criteria
for
TCS, Privacy and Security.  

Currently the HCCO membership includes a fair cross-section of the
industry
but additional participation is vital if we are to meet our goals.
Please
consider joining this very worthwhile effort.  Contact and membership
information is available on the website. 

Cheri Huber
County Privacy Officer
County of Napa 
1195 Third Street, Room 301
Napa, CA  94559
707-253-4523




 -----Original Message-----
From:   Rachel Foerster [mailto:[EMAIL PROTECTED]] 
Sent:   Tuesday, November 26, 2002 8:04 AM
To:     WEDI SNIP Testing Subworkgroup List
Subject:        HIPAA Certification & Conformance Rules

These are precisely the issues that need to be debated, argued, and
agreement reached here on what constitutes "certification." Thus, I
believe
that this group can provide immense value to the industry by not only
defining "certification" but then providing the criteria on which
"certification" will be based. This certification criteria then becomes
the
"conformance" rules that are openly developed by the industry for the
industry and then which any vendor can provide services.

Right now it's the wild wild west with each vendor offering
"certification"
but with no set of rules that the industry can use to evaluate the
claims. I
applaud Kepa for disclosing in such detail what Claredi's rules are. How
about other vendors also disclosing the rules they use - beyond just
saying
"compliance against the IG" so that we can then normalize these rules,
document them and make them available to the industry.

So, for starters, let's change the subject line. How's this for a
starting
vision: (which, quite frankly, I adapted from the ASC X12 Compliance
with
X12 report)

"Compliance with the HIPAA electronic transaction technical
specifications
as set forth in the implementation guides will constitute the basis for
deciding conformance with the HIPAA standards for three functional
levels of
semantics, syntax & interchange in terms of a business perspective and a
standards perspective."

I know some might say that we already know this, and while this may be
true
to a point, we must now develop conformance metrics against which any
consumer can measure the product, solution, or services under
consideration.

>From a Standards Perspective Compliance with X12 means conformance with
the
rules, i.e., . . . to be in agreement with the rules
X12 provides the rules. The Current term: conformance/conformity: To
meet
the requirements of a standard or specification
Conformance testing is intended to verify compliance

Why Conformance is important:
80% of problems in an open system occur due to non-compliant products
and
resulting interoperability issues
Interoperability includes conformance . . . and more:
Conformity to the standard
Software vendors collaborating by agreeing to work together

HIPAA critical success factors:
Conformity to:
Base X12 standards
HIPAA Implementation Guide specifications
Trading partner-specific specifications to achieve successful internal
application requirements

Our Challenges:
Standards are not enough to ensure interoperability. Standards are only
meaningful if implemented in a consistent way. There is a need to ensure
that implementations adhere to the standard: What is expected of
implementations in order to claim conformance - i.e., what are the
requirements? How will we know if an implementation conforms? test
suites,
test tools - Different ideas of what conformance is . . . Past
experience
may have affected view of conformance

Now, if you've stayed with me this far, I propose that rather than
arguing
about testing versus certification, that this group initiate an effort
with
the goal of developing a Conformance with HIPAA Electronic Transactions
Implementation Guides document. The ASC X12 Compliance document (which
by
the way, was developed in the early 1990's) could be a very useful
template.

Rachel Foerster






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