John: 1) The legality of a payer requiring an entity to use a specific vendor and to bear the associated cost is certainly something that needs to be addressed, but I am not certain that falls within the jurisdiction of the Testing SWG.
2) The Testing SWG promoted third-party certification as a component to good testing, and we bear responsibility to address the repercussions of this recommendation. The issue of cost is implicit in the question that was posed and ought to be considered in our response. 3) If the Testing SWG believes it best to continue to recommend single file certification as a testing best practice at this point in our compliance efforts, then we must update and revise this recommendations with what we have learned over the past year related to certification, including the issue currently under discussion, --requiring certification through one or more vendor--, and community based testing/validation/certification, adequate test data for certification efforts, etc. Thanks. Michael DeRoche 602.738.3351 cell 480.946.7200 office HIPAA Testing, Inc www.hipaatesting.com "Advanced Testing Solutions" CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message -----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Sent: Thursday, May 29, 2003 5:30 AM To: WEDI SNIP Testing Subworkgroup List Cc: WEDI SNIP Testing Subworkgroup List Subject: RE: Meeting Minutes - 5/22/2003 -- comments Marsha, I totally agree. The question from the issues database did not even mention costs so I would rather not even address it. I think that would open up a whole different box of worms. We can finalize our official response as a group during our next meeting. 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 ____________________________________________ Marsha E. Solomon/EMPL/AZ/Veri To: "WEDI SNIP Testing Subworkgroup List" [EMAIL PROTECTED] <[EMAIL PROTECTED]> cc: "WEDI SNIP Testing Subworkgroup List" 05/28/2003 07:56 PM <[EMAIL PROTECTED]> Please respond to Subject: RE: Meeting Minutes - 5/22/2003 -- comments Marsha E. Solomon Hi, I do not think that our answer on the Testing issue should include any reference to costs or responsibility for those costs. First because the person submitting the inquiry did not ask for information about absorbing any costs. I don't think SNIP should volunteer opinions on material that wasn't referenced in the inquiry. Second, I think the answer as currently written addresses any unmentioned concerns rather clearly. The regulation does not require certification, period. In our judgement, any entity which wants to require "certification" or specific third party testing needs to negotiate it in their trading partner agreements. This way its up to between the parties directly involved to identify and define costs and testing conditions. My two cents. Marsha Verizon Information Technologies Managed Care Division Phoenix, AZ Home of the Back To Back NL West Champion ARIZONA DIAMONDBACKS Phone - 602.678.6042 Fax - 602.678.6331 E-mail - [EMAIL PROTECTED] Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. "Falbowski, Ellen" To: "WEDI SNIP Testing Subworkgroup List" <[EMAIL PROTECTED]> <[EMAIL PROTECTED] cc: a.com> Subject: RE: Meeting Minutes - 5/22/2003 -- comments 05/28/2003 03:38 PM Please respond to "Falbowski, Ellen" 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 ____________________________________________ --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-testing as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org This e-mail may contain confidential or privileged information. If you think you have received this e-mail in error, please advise the sender by reply e-mail and then delete this e-mail immediately. Thank you. 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