Harry,
I am confident we've discussed this at least several times. Pardon me if I misunderstand but, your note implies that this is a secret. I bring your attention to numerous documents at the national forum level that discusses this very issue. WEDI/SNIP, AFHECT, NCHVS, all note that this remains a concern. On that we wholeheartedly agree.
Please openly consider these points:
1) It remains to be seen if the direct submission model using a PMP package is cost effective and efficient for the provider.
2) It remains to be seen if the direct submission model using PMP is cost effective and efficient for the payers.
3) It remains to be seen if the "ditto" is profitable for both payer and PM software company.
Additionally, consider this. In any software you use, you don't actually buy it and own it. You might want to take a closer look at the End User License Agreement or EULA of the software you use to read this note. You purchased the right to use it. You do not own it. Who determines what is reasonable for a company who makes millions of dollars in investment to license a product that will enhance the revenue of the user?
Is not the author entitled to some revenue for the use of his or her intellectual property? OK...no more transaction fees. The vendor now sees that revenue dry up from his revenue stream and now the provider ultimately pays a higher price to use and maintain that software package. The same one the helps him do his accounting, helps keep track of his collections and his productivity, etc... I should note that many PM vendors often uses transactions fees to offset capital costs of their R and D costs and ultimately make their software more affordable to the lowest common denominator, the small doc, who benefits greatly from having this capability.
What is that worth to you? Is x cents per transactions worth it? I can't answer that question but for some it is, for some its not.
Given these profound market forces as described above, I content the silence is deafening both from payors and providers and that silence is the secret you hear. If customers were screaming for this capability, I would have it on the market tomorrow. In fact, I can today...but again, no one is asking for it because no one at the small mid size provider level (our target market) has the resources to use and maintain it. They want to practice medicine and get paid what they are owed quickly.
I offer that you it is an illusion that HIPAA locked you into a vendor clearinghouse relationship. Nonsense. There are software companies out there that will allow you to output and input a native X12N. The way I see it, there is nothing stopping you except cost, complexity and efficiency.
Chris Brancato
[Yes, admittedly a PM vendor and a clearinghouse and a billing company.]
Director, Client Development
Chief Compliance Officer
Health Data Services
Charlottesville, Virginia.
-----Original Message-----
From: Fox, Harry [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, June 03, 2003 1:33 PM
To: WEDI SNIP Transactions Workgroup List
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]
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