I wasn't able to find anything in the Final Rule that states "a provider that is sending electronic claims today to continue to do so after HIPAA" but in the Comments and Responses on the Proposed Impact Analysis it states that reverting to paper is an option.
The following is an excerpt from page 50347 of Vol 65, #160 of the Federal Register:
3. Benefits of Increased EDI for Health
Care Transactions
Comment: One commenter stated that
the impact analysis should factor in the
cost of dismantling existing electronic
interchange systems. It was also stated
that health care providers may move
from electronic to paper submission if
they feel that the costs and burdens
associated with the new standards are
too great.
Response: There is no need to
dismantle entire systems. Rather,
provisions need to be made to
accommodate the new standards. We
believe that the benefits health care
providers are currently realizing
through EDI will continue and will
increase with the adoption of these
standards. Unlike current practices
which compel health care providers to
use multiple formats when sending and
receiving, health care providers will
only need to use one format for each
HIPAA standard when they send and
receive. If health care providers are
unwilling to upgrade their EDI system,
they have the option of using a health
care clearinghouse, or reverting to paper
claim submission.
Steve Clark
email: [EMAIL PROTECTED]
| "Marcallee Jackson" <[EMAIL PROTECTED]>
01/20/2003 03:26 PM
|
To: "WEDI SNIP Transactions Workgroup List" <[EMAIL PROTECTED]> cc: Subject: RE: Clearinghouse Connectivity and Fees - or, Have I got a deal f or you! |
Hi Ruth,
Post HIPAA, providers will send paper claims to a clearinghouse for
processing for the same reason they do today, so they don't have to
process paper claims in-house. Clearinghouses process millions of
paper claims every month, a SERVICE that they are ASKED to perform on
the part of the provider. Post HIPAA, there is no reason this cannot
continue. Just because a provider could send a claim electronically
does not mean that it must and just because a CH could complete an
electronic transaction does not mean it must, if it receives an
electronic claim from the provider with instructions to generate a paper
form, it may to do so. This is not a transaction the provider intends
to conduct electronically. It is not an electronic request for payment
from a provider to a health plan. It has no applicable requirements
under the TCS Rule.
Why would providers choose to send paper claims post HIPAA? Maybe the
provider is happy with its clearinghouse and the level of electronic
connectivity. Perhaps it has chosen to continue to do business with this
clearinghouse knowing that it does not have 100% connectivity (it
probably doesn't have much chance of getting it elsewhere anyway) and is
OK with 20% - 30% of claims being sent on paper.
I'm not aware of the portion of the Rule that requires a provider that
is sending electronic claims today to continue to do so after HIPAA.
What have you based that opinion on?
Thanks for your input on the topic!
Marcallee Jackson
Director, Healthcare Solutions
Edifecs, Inc.
Office 562-438-6613
Cell: 714-865-5059
-----Original Message-----
From: Tucci-Kaufhold, Ruth A. [mailto:[EMAIL PROTECTED]]
Sent: Monday, January 20, 2003 3:13 PM
To: WEDI SNIP Transactions Workgroup List
Subject: RE: Clearinghouse Connectivity and Fees - or, Have I got a deal
f or you!
Chris,
Your statements
"Its pretty clear to me: paper is allowed as its not an electronic
transaction. Even if it's faxed, its not a transaction by definition.
E-transactions from the provider and the CH don't need to be in standard
format. The CH is free to drop to paper but if an e-transaction is made,
it
must be in standard format."
concerns me... if the CH is contracted by the provider to send
information
to the payer in a HIPAA mandated format "dropping to paper" is not an
option. If the business function -- ie. electronic claims transmission
--
is being done today by the provider ... then the provider must do that
transaction after 10/03 in HIPAA mandated standardized format.
To whom is the CH dropping the paper too? Why would a provider use a
clearinghouse for its paper claims? Why would a provider enlist a CH to
generate more paper?
Review the definition of CH for more clarification on this relationship.
or
the FAQ ... at ...
http://aspe.hhs.gov/admnsimp/q0101.htm
http://aspe.hhs.gov/admnsimp/q0083.htm
http://aspe.hhs.gov/admnsimp/q0533.htm
Please clarify?
Ruth Tucci-Kaufhold
HIPAA Systems Analyst
UNISYS Corporation
4050 Innslake Drive
Suite 202
Glen Allen, VA 23060
(804) 346-1138
(804) 935-1647 (fax)
N246-1138
[EMAIL PROTECTED]
-----Original Message-----
From: Chris Brancato [mailto:[EMAIL PROTECTED]]
Sent: Monday, January 20, 2003 3:11 PM
To: WEDI SNIP Transactions Workgroup List
Subject: RE: Clearinghouse Connectivity and Fees - or, Have I got a deal
for you!
Bill,
You should re-read the rules scope. The rule is explicit in establishing
standard transaction sets for Electronic Transactions. The rule was only
intended to cover electronic transactions and nowhere is paper excluded
with
the exception of the CMS clause in which it's explicit unless the
Secretary
grants a waiver.
Some key areas I think contrary to your assertion.
The rule reads " The rule does not require a provider to send or accept
an
electronic transaction." FR Page 50315. If that's the case and the
provider
is permitted to transmit claim information to a "clearinghouse" in
non-standard format, there is nothing stopping the clearinghouse from
merely
printing that information to a claim form and submitting to the payer on
paper as paper is excluded. That transaction is fully compliant. It does
clearly state that if the transaction to the payer is electronic, it
must be
in standard formatting.
I continue: " Page 50316- However, the statute permits a covered entity
to
submit nonstandard communications to a healthcare clearing house for
processing into standard transactions by the health care clearinghouse
as
well as receive standard transaction through the healthcare
clearinghouse."
Its pretty clear to me: paper is allowed as its not an electronic
transaction. Even if it's faxed, its not a transaction by definition.
E-transactions from the provider and the CH don't need to be in standard
format. The CH is free to drop to paper but if an e-transaction is made,
it
must be in standard format.
Chris Brancato
-----Original Message-----
From: William J. Kammerer [mailto:[EMAIL PROTECTED]]
Sent: Monday, January 20, 2003 12:10 PM
To: WEDI SNIP Transactions Workgroup List
Subject: Re: Clearinghouse Connectivity and Fees - or, Have I got a deal
for
you!
The HIPAA TCS rule in Subparts J through R (� 162.1000 on) enumerates
the standards which the Secretary has "adopted." Paper claims are
nowhere listed as "standard" transactions for the purpose of the rule.
Whenever the rule refers to "standard" transactions, it means the
standard X12 or NCPDP transactions. You can call HCFA 1500 or UB92
paper claim forms "standard" till the cows come home, but that doesn't
make them so for the purposes of the TCS rule - which, after all, is
what we are discussing!
A clearinghouse covered entity has no choice but to "transmit standard
transactions" (� 162.930(b)) to the payer when serving as a business
associate of the provider. And "standard" does not include paper claim
forms for the purpose of the TCS rule. In the case of a claim, the only
choice of "standard" to transmit to the payer is the appropriate 837.
William J. Kammerer
Novannet, LLC.
Columbus, US-OH 43221-3859
+1 (614) 487-0320
----- Original Message -----
From: "Young, Brian" <[EMAIL PROTECTED]>
To: "WEDI SNIP Transactions Workgroup List"
<[EMAIL PROTECTED]>
Sent: Monday, 20 January, 2003 11:45 AM
Subject: RE: Clearinghouse Connectivity and Fees - or, Have I got a deal
f or you!
William,
>From what point do you make this assertion?
<snip>
It's called the 837; a paper claim is merely a non-standard claim.
<snip>
How did a paper claim, be it a H1500, UB92, State Form, TAD,
etc. become a non-standard claim? I dont recall anything from
the regulations that assert this idea. Granted the entire
driving force of Admin. Simp. TCS and the ASCA is the elimination
of paper processing; however, I dont think this fact has caused
these forms to become non-standard.
If we think that because of HIPAA, specifically the TCS section,
that the paper world will disappear, I believe this to be false
and contrary to the popular myth we all seem to be suffering.
BCY
Brian C. Young
Accu-Med Services Inc.
An Omnicare Company
300 TechneCenter
Milford, OH 45150
513.831.1207
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