Jackie,

There is more information at the American Bankers Association web site:
http://www.aba.com/NR/rdonlyres/0000654dbrdrafofylqtfela/HIPAA.pdf

It seems pretty clear in this document that the banks are probably not
at all happy about HIPAA. It also seems that they are at least accepting
the fact that banks that receive PHI from a covered entity will need a
BAA with that entity. Dated last fall, it also suggests that banks apply
for the ASCA extension (just in case) ...

The 835 IG does point out that banks are an accepted path for remittance
data to flow (dollars and data together). What is not clear in the IG is
the impact this will have on DFIs from a HIPAA Privacy perspective.


Brett Hacker, CIO
Remettra, Inc.
866-226-9641

-----Original Message-----
From: Jackie Cameron (3) [mailto:[EMAIL PROTECTED] 
Sent: Monday, March 24, 2003 9:46 AM
To: WEDI SNIP Transactions Workgroup List
Subject: Required Format for the 835


Does anyone know if a payee can require that a covered entity send them
an 835 via the ACH network?  I understand that the ACH transaction would
go through a DFI, and that there is ongoing discussion about the role of
the DFI in handling the 835.  I also understand that there are a number
of acceptable flows of data (per the implementation guide) for the 835.
For example, it is acceptable to separate the data and dollars for the
835, moving the dollars via a paper check and the data through an 835.
If this format is considered compliant, can a covered entity choose this
option and not pursue the alternative format where the dollars are moved
through the ACH network, even if a payee requests it?  Any input would
be appreciated.

Thanks,
Jackie Cameron
Product Coordinator
basys inc.
[EMAIL PROTECTED] 




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