William,
I think we're barking up the same tree here.
The critical implication of TCS "Accept ant promptly process" is that if a transaction meets the syntax rules, the receiver has to swallow it and do something appropriate with it in a timely fashion.
 
Now, what does "promptly" mean?  I know that other methods such as DDE can't offer an incentive, so the response time for standard transactions would seem to have to be at least as fast as any DDE alternative.  I also know that it doesn't reflect the time to final adjudication, which, if regulated at all, is covered by regulations totally outside the realm of HIPAA.
 
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]
 
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----- Original Message -----
Sent: Saturday, March 08, 2003 09:38 AM
Subject: Re: Accept v. Process Standard Transactions

Doug, I'll admit I really don't know the words folks in the bowels of
Healthcare IT use for describing various stages in the life of an
electronic transaction. All I know about the terms is how they're used
in the TCS regulation. "Accept" seems to come before "process," though:
� 162.925(c)(1) says health plans must "ACCEPT and promptly PROCESS any
standard transaction that contains codes that are valid..." The order
seems clear.

A snippet from the preamble is consistent with that interpretation: "For
example, a health plan cannot refuse to ACCEPT a claim from a health
care provider because the health care provider electronically submits
the standard transaction. However, the health plan is not required to
pay the claim merely because the health care provider submitted it in
standard format, if other business reasons exist for denying the claim
(for example, the service for which the claim is being submitted is not
covered)." (65 FR 50315)

Further: "For each standard transaction there are situational data
elements that are both relevant to the particular transaction and
necessary to PROCESS it." (65 FR 50322)

Again, we shouldn't get hung up on these terms. A plan always has to
ACCEPT a standard transaction (from someone it has reason to believe is
a legitimate provider, clearinghouse, or another plan).  And ACCEPTance
necessarily implies taking the interchange through the translator, if
only so the negative or positive technical TA1 and 997 acknowledgements
can be generated.

Obviously, by this time, the (syntactically valid) transaction(s) have
been mapped and are ready to be PROCESSed.  It doesn't mean the claims
are going to be paid - the plan still probably doesn't even know if the
subscriber is one of theirs! Or that all situational data is present
(e.g., subscriber's birth-date is present if the subscriber is the
patient). Now the plan can start PROCESSing. I imagine this elusive
"ADJUDICATE" is part of PROCESSing, coming after the front-end edits,
which I suppose are the first part of PROCESSing. But the EDI has long
been ACCEPTed and translated into internal database tables or flat
files, upon which PROCESSing takes place. Raw EDI data itself is never
PROCESSed itself, of course.

William J. Kammerer
Novannet, LLC.
Columbus, US-OH 43221-3859
+1 (614) 487-0320

----- Original Message -----
From: "Doug Webb" <[EMAIL PROTECTED]>
To: "WEDI SNIP Transactions Workgroup List"
<[EMAIL PROTECTED]>
Sent: Friday, 07 March, 2003 03:42 PM
Subject: Re: Accept v. Process Standard Transactions


Paul,

Accepting the claim means entering it into the adjudication system.
What the adjudication system does with it is determined by your business
rules.  HIPAA does not mandate what codes you pay for, and the
completeness necessary to determine the proper payment.  Improper coding
is probably the most frequent cause of claim rejection, and it will
continue to be so.

In the same manner, accepting a query means doing the search requested
and forming some type of response.  "Not Found" is quite acceptable if
the information given does not allow the query to succeed.

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]

----- Original Message -----
From: "Paul Costello" <[EMAIL PROTECTED]>
To: "WEDI SNIP Transactions Workgroup List"
<[EMAIL PROTECTED]>
Sent: Friday, 07 March, 2003 12:13 PM
Subject: Accept v. Process Standard Transactions

Group,

I have a question regarding "accepting" and standard transaction and
"processing" a standard transaction.

I was under the impression that in order to meet the HIPAA guidelines, a
covered entity only had to be able to accept a standard transaction, but
not necessarily process with all the data elements that come in. Also,
my understanding was that from a payer's perspective, HIPAA does not
mandate that payers completely change their core business processes in
order to process a standard transaction. Am I off-base?

For example, if a payer only processes claims that come in at the
line-level and it receives claims at the claim-level, is the payer still
obligated to pay the claim-level claims, or can it just accept the
claim-level claim (meeting HIPAA requirements) but not pay?

Another example would be when anesthesia charges are billed on a claim,
certain health plans currently require the surgical CPT code rather than
the anesthesia CPT code. If a provider, post October 16, 2003, sends an
anesthesia CPT code, payers have to accept the claim with the anesthesia
codes (understood), but do they have to pay? Can they say that their
systems only process using surgical CPT codes, so in order to get paid,
providers must send anesthesia charges using surgical CPT codes?

Wouldn't these two examples be instances where "companion guides" might
be used?

Any insight is appreciated.

Thanks,
Paul


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