Title: Message
To TWG List:
 
I'm a (somewhat experienced) HIPAA EDI consultant on assignment for the ANSI 835 transaction at a MCO Health Plan in Philadelphia. PA.   The HIPAA Project Manager and I have a difference of opinion concerning the interpretation of the HIPPA regulations with regard to a payers responsibility or requirement in reference to receiving an electronic HIPAA compliant ANSI 837 claims submission file from one (or many) of their providers.   Your assistance to resolve this difference of opinion related to HIPAA regulations interpretation would be greatly appreciated.
 
Some scenario background defining the MCO Health Plan's current (EDI) processing environment:
  • The MCO Health Plan's business is primarily Medicaid
  • They receive electronic ANSI 837 version 3041 claims submission files from at least 20 providers today
  • All inbound claims files are received via an FTP type transmission through a clearinghouse (WebMD)
  • All associated electronic remittance advice (ERA) records are generated out of their claims adjudication system in a proprietary format and transmitted to an outside vendor who is contracted to print EOBs and checks and mail them to the appropriate providers.   No "true" EDI ERA is performed with any providers today.
  • To make this scenario a little more interesting, a handful of providers receive the proprietary ERA files via a system generated email (file) attachment process  
  • For HIPAA, the MCO Health Plan is not looking for their clearinghouse (WebMD) to convert proprietary / ANSI files for them
  • The MCO Health Plan's ANSI 835 transaction project solution approach is to leave the existing proprietary files process (to the vendor for printing of EOBs and checks for the providers) alone and simply add a new standard EDI process to generate the ANSI 835 version 4010 electronic remittance advice files to be sent to providers via WebMD 
  • The MCO Health Plan will look to eventually eliminate the paper EOBs (by provider) once the providers are comfortable with processing the new HIPAA ANSI 835 files received
 
The issue / question is:  
 
Come October 16, 2003 when these 20 providers upgrade their systems and begin sending their HIPAA compliant ANSI 837 (version 4010) claims submission files to the MCO Health Plan via the WebMD EDI communications connection, will the MCO Health Plan be "required" to return response ANSI 835 transaction files  OR  do they only have to supply the HIPAA ANSI 835 response files based upon individual provider request?   
 
An answer to this question would be greatly appreciated along with any excerpts from the HIPAA regs, CFR, etc. which supports this answer.   I have reviewed the Federal Register (45 CFR Parts 160 and 162) and did not see specific language, comments /  responses, or examples pertaining to this issue / question.   Thank you all so much in advance for your time and effort in responding.   Take care.
 
 
                                                        Gary Gregus  (215-863-5137) 
                                                        HIPAA / EDI Transactions Consultant
                         

 
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