Dear Testing Group,
As a provider, I would consider "testing" and any required
"certification" to be components of the [necessary] process of "setting
up a connection" with my trading partner.  The term "enrollment" that is
often used by payers or "communities" connotes the true, lop-sided
nature of the process, in which the provider "asks" to be "enrolled" in
the community and expects to be required to jump through ALL of that
community's enrollment hoops... including any testing or certification
hoops.  All of this hoop-jumping is going to cost the provider $ and
would simply be part of his cost of setting up and maintaining each
trading partner relationship.  I believe that HIPAA is silent on the
specific elements of a TP-agreement and is also silent on how the costs
[to both parties] of setting it up should be divided.

I would not expect many provider complaints about enrollment costs,
however... because only the most sophisticated providers will even
attempt to manage direct EDI connections.  Smaller providers who are not
using DDE or dropping to paper will likely be enrolling with ONE
clearinghouse... effectively pushing their "testing and certification"
concerns onto the CH.   If we do experience such provider complaints,
they will be handled case-by-case anyway.  So I think it's fine for the
Testing white paper to remain silent on the ideal/fairest way to parse
enrollment costs.

Regards,
-C

Christopher J. Feahr, O.D.
Optiserv Consulting (Vision Industry)
Office: (707) 579-4984
Cell: (707) 529-2268
http://Optiserv.com
http://VisionDataStandard.org
----- Original Message ----- 
From: "John Singer" <[EMAIL PROTECTED]>
To: "WEDI SNIP Testing Subworkgroup List" <[EMAIL PROTECTED]>
Sent: Thursday, May 29, 2003 7:58 AM
Subject: RE: Meeting Minutes - 5/22/2003 -- cost of testing


> Actually I believe Ellen is correct. A payer cannot pass the cost of
testing onto the provider. If a payer designates a testing agency then
the payer must also pay for this especially if the testing agency is
charging for the testing of payer companion guides. Is there an attorney
on this listserve that has reviewed the regulation? I remember reading
somewhere that payers cannot pass costs to providers and clearinghouses.
>
> John
>
> --
>
> --------- Original Message ---------
>
> DATE: Wed, 28 May 2003 18:38:52
> From: "Falbowski, Ellen" <[EMAIL PROTECTED]>
> To: "WEDI SNIP Testing Subworkgroup List"
<[EMAIL PROTECTED]>
> Cc:
>
> >
> >I have a couple of comments on these minutes.
> >
> >1) Regarding the response to the testing issue submitted to the
issues
> >database, I think that if Party A requires Party B to use a
particular
> >third party's software for validation, Party A should pick up Party
B's
> >costs, if any, of using that third party's software.  However, if
Party
> >A allows Party B to choose the validation software, Party A would not
> >need to pay for the validation costs.
> >
> >2) X12N/TG2/SPWG2 (the work group that created the 824 Implementation
> >Guide Reporting IG) was notified at the February X12 meeting that
> >X12N/TG3 would be drafting a Type 1 Technical Report on which
responses
> >to use when.  Not sure of the status of that work.
> >
> >-----Original Message-----
> >From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]
> >Sent: Wednesday, May 28, 2003 3:14 PM
> >To: WEDI SNIP Testing Subworkgroup List
> >Subject: Meeting Minutes - 5/22/2003
> >
> >
> >Attendees:
> >
> >Brandi Wyatt - EDIFECS
> >Ed Hafner - Foresight
> >Miriam Paramore - PCI
> >Kerry - EPIC Systems
> >Lou Oliver - Advent Software
> >Patrick Edwards - Arkansas Blue Cross
> >Tim Collins - Kentucky Medicaid
> >Dave Frankel - EDIFEG
> >Suzan Ryder - Empire Blue Cross Blue Shield
> >John Lilleston - Verizon
> >
> >Agenda Items:
> >
> >1)  Review of Washington D.C. Conference:
> >
> >      Ed Hafner reported that the Testing breakout session went very
> >well. There were over 100 people in the room for the session and over
40
> >surveys were completed and returned to Ed after the session.  Brandi
> >also said she overheard several positive comments about the session
> >after it was over. Many people liked that we were presenting actual
> >testing experiences and statistics but some felt that there was not
> >enough time provided in the session to allow the attendees to digest
the
> >information and ask questions.
> >
> >2)  Issue from Issues Database:
> >
> >      The following issue was assigned to the Testing SWG and was
> >discussed during the meeting -
> >
> >      Can a health plan require that an entity
> > certify with a third party testing service
> > in order for the entity to begin testing
> > with a plan. If so, can the health plan
> > require that certification be obtained from
> > a particular third party and if so, any
> > caveats to that? Along these same lines, can
> > a health plan require that an entity certify
> > against its companion guidelines, with a
> > third party testing service in order for the
> > entity to begin testing with a plan. If so,
> > can the health plan require that
> > certification be obtained from a particular
> > third party? Any caveats to these two items?
> >
> >      This issue created a lot of discussion.  The HIPAA legislation
or
> >ASCA does not mention certification or verification so the issue is
> >pretty much left up to the formation of a best practice.  The group
> >agreed that requiring a third party validation/certification would
need
> >to be detailed in a Trading Partner Agreement (TPA).  If a health
plan
> >does require this type of activity, they do have the right to require
a
> >particular third party for this purpose because certain business
level
> >editing would also probably be built into the software used by the
third
> >party that was specific to that particular payer.  Not all third
party
> >vendors would have that specific editing functionality because they
had
> >not been working hand in hand with that specific health plan.  The
> >bottom line is that validation and/or certification is not required
by
> >the HIPAA legislation although it is recommended by the WEDI Testing
> >white papers.  Any requirement that is outside of the scope of the
HIPAA
> >legislation would need to be documented and agreed upon in a Trading
> >Partner agreement.
> >
> >Please review the verbiage above as we would like to draft a final
> >response to this issue during the next meeting and enter it on the
SNIP
> >website.
> >
> >4)  Next Steps for Testing SWG:
> >
> >      Sue and John had discussed a couple of topics that the Testing
SWG
> >may want to undertake as our next steps.   One idea was to develop a
> >white
> >paper as to business scenarios when the 997, TA1, 824, etc.
transactions
> >would be used.  Also, document the advantages and disadvantages of
using
> >standard transactions versus proprietary ones until the standards are
> >mandated.
> >
> >Brandi Wyatt also came up with another testing idea and will document
> >that idea to the group prior to the next meeting.  We will devote an
> >agenda item to this subject for the next meeting and try to make some
> >decisions as a group.
> >
> >Thanks!!
> >
> >____________________________________________
> >John D. Lilleston
> >Section Manager - Healthcare EDI
> >Verizon Information Technologies, Inc.
> >Phone - (813)979-3225
> >Fax - (813)978-5570
> >[EMAIL PROTECTED]
> >www.VerizonIT.com
> >____________________________________________
> >
> >
> >
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