Ruth, I'm not appreciating your reason for concern.

This very scenario happens every day. A definition of CH in the scenario
might help. These CH/aggregators I allude to are acting as clearing
houses as they are taking non-standard transactions as well as providing
print and mailing services. i.e., they might be a software vendor that
takes proprietary, non-standard claims from their clients, translates
the standard ones that are able to be submitted electronically, and
submits to a bigger clearinghouse like Unisys/Envoy-then onto the
payer-if they don't have a direct submitter relationship. The ones that
don't or have to be sent back to the provider for additional
documentation are printed out. Not a traditional CH, but a CH by
definition, nonetheless. 

The print mailing operation of this CH then submits the paper claims to
the payer direct on behalf of the provider.  I personally know a state
agency that is a Unisys client for electronic transactions only, the
ones that can't be submitted to a payer electronically because either
the payer doesn't accept them or they need additional documentation; go
to paper at the aggregator-CH level. All perfectly legal, all happens
everyday, can and will continue to happen.

Now, eventually, hopefully that level of paper will drop especially when
and if an attachment standard is agreed upon and implemented, but not
anytime soon.

I for one am not a convert to the religion that this will all disappear
come October, 2003. Personally, this arrangement I describe to you, I
predict will be increasingly common, not decreasing so because of the
high touch, high services companies like this provide to the clients
especially in regards to HIPAA. They don't want to deal with a CH as you
say, but they'll pay additional for a PM/Service Company to do it. They
just want their claims paid. No more, and certainly no less. They can
and will continue to pay small transaction fees to the PM/aggregator
because it saves them time and money by managing the process. They are
free to see patients and generate income. 




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