The path an 835 would take from a payer to the provider should be determined and agreed to between the two respective parties **and** their respective financial institutions, taking into consideration that table 2 of the 835 contains protected health information. As such, if it were to pass to the provider using the respective financial institutions and the ACH, it must be encrypted. Here's some commentary from Stanley Nachismon from CMS (thanks to Brett Hacker from Remettra) on the subject:
"...you've got to worry about first of all the storage on your site, on the bank's site, to make sure that only the right people are accessing that information and able to send it. Secondly, you've got to make sure that the transmission is protected, that as the information is being sent it's possibly encrypted or there's another method that's being used to protect the information so that if it's intercepted nobody can see it. And you also want to make sure that it's clearly going to the right place in the provider's office and that only the right folks in the provider really have access to that information. So I think there are a series of controls that would have to be implemented." Rachel Foerster Rachel Foerster & Associates, Ltd. Voice: 847-872-8070 email: [EMAIL PROTECTED] http://www.rfa-edi.com -----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] --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-transactions as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
