Forgive me if I am asking a stupid question here...but here goes. Are you saying that there is other technology out there, that will allow the payers to have their "one-offs" as a certain person likes to say..and providers can use that technology, and still get ROI (we can all have our cake and eat it too)...or that just trying to regulate an industry that has to have their "one-offs" is a hopeless task?
Mimi Hart ӿ�* Research Analyst, HIPAA Iowa Health System 319-369-7767 (phone) 319-369-8365 (fax) 319-490-0637 (pager) [EMAIL PROTECTED] >>> "Christopher Feahr" <[EMAIL PROTECTED]> 06/02/03 12:41PM >>> (Please forgive the cross-posting to "business issues", but I think it belongs there too) Dear Peter, Thank you again for this thoughtful and evenly balanced statement of the problem and proposed solutions. I would offer a few comments, however, on your new 6.18 section that answer's Rachel's question "Is legal relief of any type just treating symptoms and not the illness?" First, we need to keep in mind that we have 2 problems to solve: the deadline and the original cost/inefficiency problem that TCS was intended to mitigate. I agree that the deadline problem is tricky... but it's also completely artificial. Give me a few hours with the Federal register and a pail of White-Out and I can make that problem disappear! The administration can stick to its guns and derail the healthcare industry right before an election year... or it can maintain the status quo while we ALL (providers included) take a deep breath and a second look at the ORIGINAL problems TCS was intended to fix. In my view, this is a no-brainer for President Bush's Administration. "Managed Legal Relief" is by far the most detailed and intelligent proposal I have seen for averting the Certain Disaster of obeying the law and/or the Tragedy of entirely calling off our noble effort to remove cost/error from healthcare. At the same time, however, we MUST address the questions that Rachel and I and many others are raising about the wisdom of using EDI as the standard in an industry as important and as fragmented as healthcare. There are only two positions that I can imagine us adopting with respect to the present Rule and EDI: 1. EDI is a good and workable concept for our industry... today... and people just need to get more serious about implementation. OR 2. EDI is physically incapable of removing net cost or improving net efficiency in healthcare... that both it and the regulatory process that is presently driving it are, in fact, ADDING cost/complexity to an industry already overburdened with its core mission of delivering care. Does anyone in healthcare anticipate true ROI from the existing Transaction Rule... even for the billions we have already invested in EDI? What about ROI for EDI-development dollars spent over the next couple years? These questions must be answered WHILE we struggle with the self-inflicted problem of the deadline. Until a few weeks ago, it was considered "in very bad taste" to openly criticize the federal government's plan or suggest it will not accomplish its stated objective. If I'm really the only guy in the country who thinks EDI is barking up the wrong tree and that pouring additional development dollars into it would be a BAD idea in Q4 of 2003... then I guess I'll have to shut up and go back to being an eye doctor. If you think I'm on the right track, however... but simply believe we'd never be able to execute such a dramatic course change in such a short time... then I ask you to remember two concepts: TRAIN WRECK and ELECTION YEAR. There is plenty of motivation here for a dramatic course change! I think it would be very helpful to step WAY back from HIPAA for a moment and ask ourselves, "What is the most sensible course of action for ALL industry stakeholders and for our Patients... from this moment forward?" Best regards, -Chris Christopher J. Feahr, O.D. Optiserv Consulting (Vision Industry) Office: (707) 579-4984 Cell: (707) 529-2268 http://Optiserv.com http://VisionDataStandard.org ----- Original Message ----- From: [EMAIL PROTECTED] To: WEDI SNIP Transactions Workgroup List Sent: Sunday, June 01, 2003 8:04 PM Subject: Re: Transition paper I would like to thank those who have sent comments. Three so far have been to the listserv; so I would like to answer those in the listserv format. A. To David Frenkel, who asked if I had tested the conclusions of the paper in Washington (see below). David, thanks for your comments. I always find your emails must reading. My expectation is that the concept of administrating the implementation using status information linked to legal relief may not be intuitively attractive to HHS. I thought it needed to be said anyway. Although it is a small amount of work now, it stands the better chance of controlling the delay such that we would not face it anew, say, a year from now. I would hope the give it close examination. Saying that, I have very high regard for HHS and CMS administration and will contentedly go along with the outcome. The paper also has other value, including: - description of the risk we are facing - description of the causes of the risk, c.f. 6.7 - discussion of, as WEDI asked, what it means to be compliant; c.f 1.3, 5.1.2, 5.1.4, 6.1, and 6.2 - description of the criteria for waiver of penalty; c.f. 2.3-2.6. B. To Susan Hollabaugh, who asked, since we are proposing to gather information anyway, why not get the underlying or internal status information that in most cases is driving the pace of implementation. Thanks, Susan, for bringing up a great point. I have added a new paragraph 6.17 to the paper should it ever go out with another new version. The paragraph is reprinted below. C. To Rachel Forster who complimented me by including a reference to the paper along with the WEDI and AHA letters and with Kepa's 3rd essay on market forces. Rachel, I agree heartily with the potential for new technology but am not so sure about its relevance to today's problem. I have added a new paragraph, 6.18, quoted below, on this and some related subjects. Again, thanks you all for even reading the paper. It is an entertaining subject. Peter Peter Barry Peter T Barry Company Independent Consulting Health Care and Information Systems Ozaukee Bank Building 1425 West Mequon Road Mequon Wisconsin 53092 (414) 732 5000 (national cell) [EMAIL PROTECTED] -------------------------------------------------------------------------- ----------------- New paragraphs added to the paper: 6.17 Why just gather the status between trading partners? This paper only proposes to gather the status between trading partners. It does not propose to gather information on internal projects of a covered entity even though internal information might be highly indicative of eventual progress. But internal information might be unnecessarily intrusive, more subjective, and gathering it would definitely burden the industry. Instead, this paper proposes to index only the more objectively defined status on EDI exchange. It is simpler, oriented to results rather than project steps, and does not burden the industry. 6.18 Is legal relief of any type just treating symptoms and not the illness? One line of discussion is that this paper, the WEDI letter, AFEHCT and AHA testimony, Drs. Braithwaite's and Fusile's report, and Dr. Zubeldia's essay on market forces represent Band-Aids, that they do not address the underlying problem. The underlying problem is variously suggested to be (1) that government fiat is unworkable, (2) it places undue or inequitable demand on smaller entities, (3) it ignores the financial plight of providers, (4) it is high distraction from a Medicare/Medicaid funding crisis, and (5) it is too complex, cumbersome, and costly to implement. It is frequently suggested that EDI technology is old and problems would be much less if more modern technology were used instead. I view all these points as interesting topics for discussion. They are more than philosophic discourse, but they do not address the present problem of October 16th; so they completely miss the point. Since there is no way the industry can meet the deadline, the government has only two possible actions: (1) abandon the effort, or (2) give relief from the deadline. Abandonment is defeatist, ignores the excellent gains and potential good that will come of the present effort, and would cause its own heavy costs and dislocation. It is also politically infeasible. So the only viable course is to provide legal relief. The central thesis of this paper is that the relief should be linked with status information to enable effective administration. Peter Peter Barry Peter T Barry Company Independent Consulting Health Care and Information Systems Ozaukee Bank Building 1425 West Mequon Road Mequon Wisconsin 53092 (414) 732 5000 (national cell) [EMAIL PROTECTED] --------------------------------------------------------------- Peter, Have you tested the political waters in Washington with your conclusions? There seems to be bigger distractions in Congress in regards to Medicare drug benefits and diminishing Medicare reimbursements. On top of all this next year is a presidential election. It is already well known that most hospitals in the US are already having financial problems and there appears to be little effort to alleviate this regardless of the HIPAA issues. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 612-237-1966 ----------------- Forwarded Message: Subj: RE: Transition Paper Date: 5/30/2003 9:16:27 PM Central Daylight Time From: [EMAIL PROTECTED] To: [EMAIL PROTECTED] Sent from the Internet (Details) Peter, I found your paper full of great ideas and I am circulating it within my own organization. I do have one concern regarding the gathering of status information. I work for a provider organization and we do use a clearinghouse but our clearinghouse only knows what our status is with them. However, there are many steps that lead up to the point of even submitting claims to our clearinghouse to test. 1)status of our PMS HIPAA upgrade, 2) our competence level with the IGs 3)status of our payer surveys and the collection and review of Companion Guides 4)data gathering related to the requirements laid out in the companion guides 5) completion of a gap analysis and all the other countless things I have forgotten to mention. If our CH uploads information regarding our HIPAA status with them to the Data Gathering Website, it would not be a true reflection of where we (the provider) are in the implementation efforts. If we are trying to determine how ready the industry is then it seems to me we need to know this type of information as well. For example, we have done a Work Flow Inventory, a Gap Analysis, modified many of our Patient Registration Forms to collect new date, developed a comprehensive training program to train staff to collect the new data, developed materials to explain to patients why we are asking all these new questions, begun testing with a third party organization (prior to sending to our CH), etc... We are in a very different place than many of the other providers that submit to the same CH that we use, but the CH does not record or store this type of detail. If we are going to take the time to gather industry wide detail on where we are, don't we need to know this type of information? Would the Clearinghouses be expected to gather this type of information about their providers? Susan -----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Sent: Thursday, May 29, 2003 1:44 PM To: WEDI SNIP Transactions Workgroup List Subject: Transiion Paper Attached is an updated copy of the Transition paper I presented at the WEDI conference last week. This builds on WEDI positions, but it does not in any way represent anyone's opinion by my own, errors and all. If it is useful to you, you may freely distribute it. Besides its recommendations, it may offer helpful description of the transition problem and business strategies to deal with it. It also addresses the contest between technical perfection and general conduct of business, the latter prevailing to my thinking. Peter Peter Barry Peter T Barry Company Independent Consulting Health Care and Information Systems Ozaukee Bank Building 1425 West Mequon Road Mequon Wisconsin 53092 (414) 732 5000 (national cell) [EMAIL PROTECTED] --- The WEDI SNIP listserv to which you are subscribed is not moderated. 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