I�ll try to articulate and summarize the many views expressed on this topic till now 
since I first wrote on this topic after I got back from the WEDI/SNIP HIPAA summit in 
Phoenix.

First some listserver issues:

1. Thanks to everybody who participated in the on-going debate (with different but 
similar words in the Subject) for proving that we can all buy alcohol and tobacco and 
firearms on our own ;) and don�t need adult-supervision of the co-chairs who are 
people like us ! ;)  This list serv has a higher purpose than to post conference calls 
agenda before and minutes after ;).
2. What�s up with that REPLY BUTTON ;)
3. Why do I get two copies of all the emails sent to the testing and other listservs?

Now to the topic at hand...

First and foremost:

Thanks to all those who participated in this debate very professionally.

Most important:

CERTIFICATION IS NOT REQUIRED under HIPAA by law for Transactions, Code-Sets and 
Privacy, is required only for security.

Like Privacy and Security are about �Use and Disclosure�, when it comes to 
Transactions testing, one VALIDATES TRANSACTIONS/TESTS and CERTIFIES a 
PROCESS/PRACTICE.

Testing for HIPAA compliance does NOT have to involve validating business logic.

The analogy I can think of is, HIPAA compliance testing is like trying to catch 
compile time errors and trying to catch business logic errors is like trying to catch 
run-time errors using a debugger.

The other analogy I used before is that of ANSI C (programming language) is a standard 
set by ta da... ANSI.  All the native compilers of different vendors HAVE to stick to 
the standard.  Another analogy is that of GL (Graphics Language) becoming Open GL 
after vendor consortium.

So... it is important for all the vendors to agree on same errors and similar warnings 
when offering validation-testing tools/services for HIPAA compliance and not 
necessarily biz logic.  Biz logic testing is extra and a nice FREE-BEE from a vendor.  
And dicing and slicing a transaction in many ways still is NOT CERTIFICATION but does 
provide very useful information that lends to CERTIFICATION.

Coming to the need to define the word Certification properly and help the HealthCare 
Industry....

It is now more than obvious from the on going debate, the popular perception out there 
is, that the word Certification was arbitrarily chosen and mis/ab-used ever since by 
WEDI/SNIP recommendations through the Transaction Testing and Certification white 
paper (and is more aligned with some business plan).   It is also obvious that 
WEDI/SNIP did not and could not come up with the proper usage of the word 
Certification till now.  CERETIFICATION is a well defined word and widely used concept 
in the industry in other walks of life and can be and should be adopted and adapted 
from existing things into the healthcare industry as well and we need not come up with 
some arbitrary definitions that suits some.

In that sense, HCCO can and should offer assistance to properly define 
Conformance/Practice/Process Certification.  Many people, like myself, are members of 
HCCO and write to this listserv regularly.  So assistance or participation... same 
thing.  A little competition between HCCO and WEDI/SNIP is also healthy.  Competition 
from competent people only helps Covered Entities.

The accpetable error rate is a mutually accpetable biz decision and depends on the 
errors� severity and not just the error itself... from bug-tracking approving software 
by QA guys 101.

Vendors need CEs and CEs need vendors.  There is a tremendous value in third party 
testing tools/service for VALIDATION.  CERTIFICATION?  It�s different ballgame... 
talking of which I�ll end this note with �Take me to the Ball Game....�

Thanks for reading till now.  Please debate on...

Best Regards,  --Rama.

---
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