Mimi, Actually, that's a great question! And the answer is YES! EDI is based on the notion of rigid business requirements coming down "from on high"... take 'em or die... my way or the highway. Web Services and ebXML approaches, on the other hand, are based on the notion that each trading partner exposes HIS OWN business and application requirements, capabilities, and limitations... via public registry. If someone wants to trade with him, their system looks up his capabilities, combines that information with their own capabilities and limitations... and auto-negotiates an optimal trading relationship. If he wants to trade with someone else... he does the same discovery-auto-negotiation process that his partners have used to hook up with him. Everyone is a "peer" and everyone has the same shot at playing.
Without the discovery-negotiate aspect, EDI must try in advance to imagine the UNION of everyone's possible trading requirements... and rigidly structure them into a SINGLE standard used by the entire trading "community" for each transaction. This works OK (not great, but OK) when the community is "people who want to sell to Wal-Mart"... in which case, Wall-Mart might white-out much of the X12 standard as "not used" and maybe make a few other needed alterations for a Wall-Mart IG. That's why X12 implementations have been so gorilla-driven over the years and why the X12 development process has not been terribly concerned with rigid conformance metrics, perfectly normalized data dictionaries, etc. The vast majority of X12's pre-HIPAA implementations embody the one-off requirements of the Alpha Male who happens to be driving each "community". When you apply this model to 600,000 providers who MUST communicate with 6000 payers, however, it falls apart. I've been ranting for a couple years about needing provider input in the SD-process, but if we actually DID insert provider requirements into the X12 process, it would crash the system. If the Workgroup discussion process didn't melt down under such pressure, imagine the size of the 837 IG if it represented the union of payer AND provider requirements! But that's exactly what we must do... consider everyone's requirements for all lines of business in healthcare... requiring us to apply a different standards development paradigm. We require the message development framework proposed by HL7 and UN/CEFACT. As I have said in previous posts, Payer Gorillas deserve to have as many of their one-off requirements met as humanly possible... as do their Provider trading partners. We've hit (some would say, exceeded) the limit of what we can reasonably do with increasingly bloated X12 IGs. All we need is an EFFICIENT way of registering and addressing each business's requirements. One of those requirements for Payer A might very well be "the use of 4010A1 for claims"... but for Payer B, it might be some flavor of XML. As long as my system can EFFICIENTLY discover and accommodate the requirements of my big partners, I'm happy. By the way, Common Sense (the universal desire to QUICKLY move a reasonably good standard through vetting and balloting) will drive this process... we do not need a regulation driving it. All the regulation has to say is that all agreements have to be reached by consensus and that ALL stakeholders must be given COMPETENT representation throughout. The last two requirements will ensure Fairness. So... Common Sense is the driver... Fairness is the guide... and our [much less granular] Federal Regulation can sleep quietly by the door in case somebody tries to get tricky and sneak Unfairness into the process. 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: "Mimi Hart" <[EMAIL PROTECTED]> To: <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]> Sent: Monday, June 02, 2003 10:56 AM Subject: Re: Transition paper > 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. > 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 > > > --- > 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 > ********************************************* > > This message and accompanying documents are covered by the Electronic Communications Privacy Act, 18 U.S.C. �� 2510-2521, and contain information intended for the specified individual(s) only. This information is confidential. 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