Mimi- Amen to that! Just because you CAN do something does not make it good business sense.
The opinions expressed here are my own and not necessarily the opinion of LCMH. Douglas M. Webb Computer System Engineer Little Company of Mary Hospital & Health Care Centers [EMAIL PROTECTED] "This electronic message may contain information that is confidential and/or legally privileged. It areIt is intended only for the use of the individual(s) and entity named as recipients in the message. If you are not an intended recipient of the message, please notify the sender immediately and delete the material from any computer. Do not deliver, distribute, or copy this message, and do not disclose its contents or take action in reliance on the information it contains. Thank you." ----- Original Message ----- From: "Mimi Hart" <[EMAIL PROTECTED]> To: "WEDI SNIP Transactions Workgroup List" <[EMAIL PROTECTED]> Sent: Friday, November 15, 2002 08:51 AM Subject: Re: 275 attachment > Kathy - if a payer of ours was to do this, we would be forced to go all > paper to them, because I anticipate it will be years before our vendors > make this transaction modification to their system. Is that, as a payer, > what you really want? > > Mimi Hart ӿ�* > Research Analyst, HIPAA > Iowa Health System > 319-369-7767 (phone) > 319-369-8365 (fax) > 319-490-0637 (pager) > [EMAIL PROTECTED] > > >>> [EMAIL PROTECTED] 11/14/02 08:21PM >>> > Kathy, > > If it showed up in the regulations, it would probably be in the as yet > unpublished Claim Attachments rule. I didn't cite anything official > because I am not aware of anything official that would compel this > interpretation. > > One area where this has come up is with vision claims. A major vision > payer reportedly asks for many technical details regarding lenses and/or > eye measurements that are not part of the standard, and is reportedly > intending to continue to require them under HIPAA. Their authority for > doing that could be their right to require claim attachments, and I > believe that that was the occasion for one discussion where Stanley > Nachimson of HHS is reported to have made such a statement. > > But this hasn't been fully sorted out yet, and I'm not sure that I > agree with the reasoning. It would seem that the right to require > attachments at all would imply the right for some sliver of the industry > to require them consistently. I.e., it may not be needed for all health > care claims, but it might be needed for virtually all claims submitted > by a given specialist due to the nature of that specialty. > > We have a similar issue with the interpretation of the DDE rule, where > a payer could conceivably ask for more information in that environment > than is supported by the claim standard, but argue that that is OK > because it constitutes a claim attachment transaction, rather than an > addition to the claim transaction. Minus the attachment rule, I don't > know of anything in the rules that would prohibit this. And, even with > an attachment rule, and with an initial group of standardized > attachments, it might still be several years before a specific type of > attachment was standardized, and there might not be any particular limit > on what could be requested until that particular type was standardized. > > All of that said, on a practical level, I would prefer that payers went > on a data diet by revising their benefit plans is such a way as to > reduce their need for attachments and for much of the data currently > included in the claim-related transactions. Many have done just that to > reduce their own administrative expenses. But I would expect that the > government plans would be the worst offenders when it comes to asking > for all kinds of additional information, whether that be in the form of > claims data, attachment data, certifications, authorizations, or > whatever. > > So, in sum, I think that it is reasonable to suggest that there might > be a problem if a given payer were to request additional data with every > claim, whether they called it an attachment or not. But it may still be > several years before there is any meaningful restriction of their right > to do so, unless HHS itself comes up with something more specific than I > have heard about. > > - Zon Owen - > (808)597-8493 > > PS: Maybe Maria Ward or another claim attachment guru can add a > helpful comment or two. > > ----- Original Message ----- > > From: Carlin, Kathy (Contractor) > To: WEDI SNIP Transactions Workgroup List > Sent: Thursday, November 14, 2002 11:05 AM > Subject: RE: 275 attachment > > > Zon, your comments are very encouraging. If payers can require > attachments for any data they want, then the standards lose their > effectiveness, and providers are back in the business of supporting > separate requirements by payer. Is anything being done to build this > into the regulations? > > Thank you, > > Kathy Carlin, Principal Consultant > Siemens Medical Solutions > > UCLA Phone 310-301-5219 > UCLA email: [EMAIL PROTECTED] > Siemens Voicemail 610-219-2067 > Siemens email: [EMAIL PROTECTED] > > > -----Original Message----- > > > From: Zon Owen [mailto:zon4@;earthlink.net] > Sent: Thursday, November 14, 2002 10:56 AM > To: WEDI SNIP Transactions Workgroup List > Subject: Re: 275 attachment > > > > Suzanne, > > > > I can't cite a regulation or an HHS FAQ on this, but Stanley Nachimson > of HHS has stated on a number of occasions something to the effect that > an attachment that is required with every claim is the equivalent of > adding data to the claim standard, and would thus be problematic. I.e., > if it is needed all of the time, it should be part of the claim, not > part of an attachment, and you can't unilaterally add data to the claim > transaction. So you might want to contact HHS directly on this. > > > > - Zon Owen - > > (808)597-8493 > > > > ----- Original Message ----- > > > > > From: Suzanne Azariah > > To: WEDI SNIP Transactions Workgroup List > > Sent: Tuesday, November 12, 2002 8:04 AM > > Subject: 275 attachment > > > > Dear Group Members, > > We would like to know if we can require a 275 for every 837. This > would give us the ability to collect data such as DSMIV codes and more > definitive ethnicity codes. Is there a reason why this cannot be done? > > > Thanks. > Suzanne --- 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/. 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