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Harry,
Amen to that!
It's in my plans only because I write our software. It's
a lot easier on a specialized system [a lot of things just don't
apply].
The opinions expressed here are my own and not necessarily the opinion of
LCMH.
Douglas M. Webb Computer System Engineer Little Company of Mary
Hospital & Health Care Centers [EMAIL PROTECTED]
"This electronic message may contain information that is confidential
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----- Original Message -----
Sent: Tuesday, June 03, 2003 12:33
PM
Subject: RE: Transition paper
With all the talk about EDI I am continuously surprised that no
one talks about what I think of as one of the open secrets of HIPAA
TCS--Most providers, through their practice management systems are not
submitting EDI at all, but rather, using a variety of 'HIPAA Compliant'
flat file or legacy upgraded formats to clearinghouses who are converting
these flat files, (and in some cases adding or correcting data content for
compliance), into an EDI 837. Many of these flat file formats are
proprietary to a clearinghouse further locking a vendor into a specific
clearinghouse. Rather than disintermediate the clearinghouses, HIPAA has
locked us further into working with clearinghouses indefinitely since most
PMS vendors, particularly for professional claims, have not added EDI to
their systems. So when someone writes about "the wisdom of using EDI", most
of the PMS vendors I have talked to have upgraded their systems for HIPAA
required content, but EDI is not in their
plans.
Thanks,
Harry
Fox
----------------------------------------------------- Harry D.
Fox Vice President, e-Commerce Coventry Health Care 6705 Rockledge
Drive, Suite 900 Bethesda , MD 20817
Work:
301-581-5797 Fax: 301-493-0720
Coventry Health
Care has a new look on the internet! Visit http://www.coventryhealth.com <http://www.coventryhealth.com/>
-----Original
Message----- From: David Frenkel [mailto:[EMAIL PROTECTED] Sent: Tuesday,
June 03, 2003 11:39 AM To: WEDI SNIP Transactions Workgroup
List Subject: RE: Transition paper
Rachel,
You are
making some broad generalizations. It would be useful to at
least cite some published metrics to support your conclusions. I can
mention that one of the titans of US industry, Microsoft, continues to
expand its EDI program on Microsoft OS platforms. One of Microsoft's
recent largest EDI rollouts was for their Xbox product to get on the
shelves of another industry titan Wal-Mart (which has pharmacies covered
under HIPAA). I can site numerous other companies that are expanding
their EDI programs both on mainframe and non-mainframe. I would
disagree about your concept of legacy EDI only on mainframes. There
are many definitions of mainframes but the mainstream concept of a
mainframe computer is an IBM 30xx and its variants although there are more
inclusive definitions.
EDI is workable it is the older
'brittle' adjudication systems I think you are referring to that are
causing the real
problems.
Regards,
David
Frenkel
Business Development
GEFEG USA
Global Leader in
Ecommerce Tools
www.gefeg.com <http://www.gefeg.com>
612-237-1966
-----Original Message----- From: Rachel
Foerster [mailto:[EMAIL PROTECTED] Sent: Tuesday, June 03, 2003 12:38
AM To: WEDI SNIP Transactions Workgroup List Subject: RE: Transition
paper
Miriam, with all due respect, while I agree that
for many industries and large companies that have invested in a traditional
EDI infrastructure are not walking away from it....they are NOT continuing
to invest more dollars and resources into traditional EDI. Traditional EDI
is based on legacy mainframe batch processing concepts, is much too
abstract and much too brittle to support the 21st century's needs for
global interoperable electronic business
messaging.
For the life of me I don't see why healthcare
should implement something that other industries did 20-30 years ago
because it was the available solution THEN simply because it worked BACK
THEN. It's not the foundation on which to build for the 21st century and
for healthcare to continue down this path, it will be spending tens of
billions of dollars to implement a brittle, unworkable legacy capability
while the rest of the world has
moved on.
Rachel
Rachel Foerster
Chief
Executive Officer
Rachel Foerster & Associates, Ltd.
Ideas -
Promotion - Innovation
Voice: 847-872-8070
email: <mailto:[EMAIL PROTECTED]> [EMAIL PROTECTED]
<http://www.rfa-edi.com/> http://www.rfa-edi.com
-----Original
Message----- From: Miriam Paramore
[mailto:[EMAIL PROTECTED] Sent: Monday, June 02, 2003
2:47 PM To: WEDI SNIP Transactions Workgroup List Subject: RE:
Transition paper
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.
-----Original Message----- From: Christopher Feahr
[mailto:[EMAIL PROTECTED] Sent: Monday, June 02, 2003 1:41 PM To: WEDI
SNIP Transactions Workgroup List Subject: Re: Transition
paper
(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://Optiserv.com <http://VisionDataStandard.org> http://VisionDataStandard.org
-----
Original Message -----
From: [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]>
To: WEDI SNIP Transactions <mailto:[EMAIL PROTECTED]> 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
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