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Dr.
Feahr, Peter et al,
With
all due respect, my 2 cents.
EDI is
still the backbone of most of the sexy e-commerce that is running other
industries -- manufacturing, retail, etc. Even those that are implementing
cool XML and web stuff still have an EDI backbone under the covers.
Healthcare needs the backbone that has proven successful in other
industries and that is why I don't think HIPAA is barking up the wrong
tree. To try and create consensus in a non-X12 standard -- after it took a
decade to get it for X12 -- would simply have us asking the same questions a
decade from now about what is wrong with that standard.
Best Regards,
Miriam J. Paramore (Co-Founder and President of HAWK)
President &
CEO
PCI: e-commerce for healthcare
9001 Shelbyville Road
iTRC
Building
Louisville, KY 40222
502-429-8555
www.hipaasurvival.com
===========================================
This email contains
confidential information intended only for the named addressee(s). Any use,
distribution, copying or disclosure by any other person is strictly
prohibited.
(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
----- Original Message -----
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]
---
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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.
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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.
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