Re: Non-compliant inbound transactions

[Ken Steen]

Title: Message

Rachel -   While I don't disagree with your assesment, I do know that at the WEDI conference last week in Chicago, Stanley said that all enforcement would be complaint driven.   If I, as a clearinghouse, have a contract with a provider to convert standard 835 data sets into a proprietary format.  In my scenario, a major payer sends a CD containing an 835 data set to my client, who then forwards it to me.  When I read the data set, I discover that in Loop 1000A, Segment N1 (Payee Identification) field N103 ( which is required) is blank.  When I read N104, I find that the ID matches my cross reference table for this payer and provider.   Who's going to complain if I go ahead and process the transaction?  My thought is to provide a notification to my client as to what happened and suggest they contact the payer and make them aware of the problem.  I do suspect that if I do not process the file and be "HIPAA compliant" in the strictest sense of the wording, and it takes a couple of months before the payer corrects the data sets, that my client will have a prefix of "ex".    By the way, this scenario actually happened during one of my tests about three weeks ago.  I asked my client what his response would be, and you guessed it .........   While I am not advocating ignoring the regulations, I surely do believe that there are cases in which the reciever of named transactions will, in real life, be processing data, even though there are "HIPAA errors".    Ken Steen Apollo     ----- Original Message ----- From: Rachel Foerster To: WEDI SNIP Transactions Workgroup List Sent: Thursday, March 13, 2003 1:40 PM Subject: RE: Non-compliant inbound transactions Linda, the language below from the electronic transaction final rule says it all....a covered entity must conduct the transaction as a standard.....conduct includes inbound and outbound in my opinion.   � 162.923 Requirements for covered entities. (a) General rule. Except as otherwise provided in this part, if a covered entity conducts with another covered entity (or within the same covered entity), using electronic media, a transaction for which the Secretary has adopted a standard under this part, the covered entity must conduct the transaction as a standard transaction.   Rachel Foerster Rachel Foerster & Associates, Ltd. Voice: 847-872-8070 email: [EMAIL PROTECTED] http://www.rfa-edi.com ################################################################# This transmission may be confidential or protected from disclosure and is only for review and use by the intended recipient.  Access by anyone else is unauthorized. Any unauthorized reader is hereby notified that any review, use, dissemination, disclosure or copying of this information, or any act or omission taken in reliance on it, is prohibited and may be unlawful.  If you received this transmission in error, please notify the sender immediately.  Thank you. -----Original Message----- From: Linda Young [mailto:[EMAIL PROTECTED] Sent: Thursday, March 13, 2003 11:40 AM To: WEDI SNIP Transactions Workgroup List Subject: Non-compliant inbound transactions I would really appreciate your help on this very basic question. As part of HIPAA compliance I understand that we must send compliant outbound EDI transactions.  My question is, are we supposed to reject inbound transactions that are not HIPAA compliant?  Can anyone point me to a section in the final rule or federal register (or any HIPPA official document or IG) that states that we should reject inbound transactions that are not HIPAA compliant? Thanks Linda Do you Yahoo!? Yahoo! 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