Only if that clearinghouse will be able to receive, reformat in cases
and transmit in the HIPAA format - not sure if WebMD is able to do that
yet.

Thanks,
Grace Upleger
Vanderbilt Medical Center



-----Original Message-----
From: David Frenkel [mailto:[EMAIL PROTECTED] 
Sent: Tuesday, June 03, 2003 1:59 PM
To: WEDI SNIP Transactions Workgroup List
Subject: RE: Transition paper


Harry,
I also saw some where (sorry no cite) that WebMD has around 50% of the
CH business.  This makes it a little easier for a PMS if they only want
to work with only one CH.

Regards,

David Frenkel
Business Development
GEFEG USA
Global Leader in Ecommerce Tools
www.gefeg.com
612-237-1966

-----Original Message-----
From: Fox, Harry [mailto:[EMAIL PROTECTED] 
Sent: Tuesday, June 03, 2003 12:33 PM
To: WEDI SNIP Transactions Workgroup List
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]
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