Posting it here from the Biz issues listserv, as I mentioned in the conference call 
today morning.  --Rama.

-----Original Message-----
From: Jensen, Martin [mailto:[EMAIL PROTECTED]
Sent: Friday, June 13, 2003 3:39 PM
To: WEDI Business Issues Subworkgroup List
Subject: RE: Who Pays for Testing?


Peter - 

As usual, your arguments are well thought out, rational and 
reasonable.  However, the law does not designate any single testing 
service as defining what "HIPAA Compliant" means.  For the payer to 
insist (as only payers have the power to do) that providers use a 
PARTICULAR testing service, they have created an obstacle to my 
sending them a compliant transaction, which the regulations clearly 
disallow.  Should the payer enter into a financial arrangement with 
said service to share the revenues thus generated, they have charged
me for putting that obstacle between my compliant transaction and
their front door. 

We invested a lot of research identifying a translator vendor that 
could validate against the X12N standards.  We then invested a good 
deal more in the tool and its validation engine.  We now continue to 
cross-check the output of that translator against one of the free 
services available to the industry. 

For a trading partner to insist that I subscribe to a different 
service, under the presumption that my transactions are noncompliant, 
represents an unfair burden on MY testing resources.  When they accept

money under that requirement, they violate Federal law. 

What is more, all our testing has proven that no one has cornered the 
market on HIPAA compliance.  The only thing that matters is getting a 
claim past a particular payer's edits, whether they be loose, tight, 
or outright noncompliant. 

-----Original Message----- 
From: [EMAIL PROTECTED] 
To: WEDI Business Issues Subworkgroup List 
Sent: 6/13/2003 3:39 PM 
Subject: Who Pays for Testing? 

I am attaching excerpts from two papers that bear on the listserv 
discussion about who pays for testing.  Both papers are available 
electronically on request and may be freely distributed. 

Peter 

Peter Barry 
Peter T Barry Company 
Independent Consulting Health Care and Information Systems 
Ozaukee Bank Building 
1425 West Mequon Road 
Mequon Wisconsin 53092 
(414) 732 5000 (national cell) 
[EMAIL PROTECTED] 








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