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Agreed, Doug! Again, there are no real barriers
here....just bogus ones trumped up by an insurer that wants to be an
obstructionist. Sounds to me like they may be having cash flow problems and want
to put up all kinds of obstacles for paying out what they have
contractually agreed to in their health plan.
Rachel
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Rachel,
Applying just about any encryption algorithm (including a
simple Caesar code) to the SSN would generate an ID that would pass the
California requirements with minimal effort on the payer's part.
(Fixed algorithm, single key for the payer, encrypt/decrypt
on the way in and out of the back end system).
What's their problem? A no-sweat solution has been
available longer than that law has been in existance!
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
and/or legally privileged. It is intended only for the use of the
individual(s) and entity(s) named as recipients in the message. If you
are not an intended recipient of the message, please notify the sender
immediately, delete the material from any computer, do not deliver,
distribute, or copy this message, and do not disclose its contents or take
action in reliance on the information it contains. Thank you."
----- Original Message -----
Sent: Saturday, September 20, 2003
03:35 PM
Subject: RE: Insurance cards with no
Insured ID
Chris, the following highlight of this law seems to indicate
that the use of
the SSN is allowed. Printing a SSN on an insurance card
is expressly
prohibited.
Rachel
CALIFORNIA'S NEW SOCIAL
SECURITY NUMBER CONFIDENTIALITY LAW
California's Social Security
Number Confidentiality Law takes effect on July
1, 2002. Identity theft
in America is on the rise, and this new law attempts
to protect against
it by limiting the use of social security numbers by
private entities.
Most employers use social security numbers for reporting
and
identification purposes, and this law may well impact the way
you
currently use social security numbers.
Effective July 1, 2002,
"any entity or person," excluding state and local
governmental agencies,
is prohibited from:
Publicly posting or displaying an individual's
social security number;
Printing an individual's social security
number on any card required to
access products or services provided by
the employer. (This includes social
security numbers on insurance cards,
employee identification cards, security
badges, and similar
identification tools);
Requiring an individual to transmit his or her
social security number over
the Internet, unless the connection is secure
or the social security number
is encrypted;
Requiring an
individual to use his or her social security number to access
an Internet
Web site, unless a password or unique personal identification
number or
other authentication device is also required to access the Web
site; and
Printing an individual's social security number on any materials
that are
mailed to the individual, unless state or federal law requires
the social
security number to be on the document mailed (e.g., mailing
I-9 and W-2
forms). Notwithstanding this provision, applications and
forms sent by mail
may include social security numbers.
The
new law has two exceptions applicable to employers:
It does not
prevent the use of social security numbers for internal
verification or
administrative purposes; and
It does not prevent the use,
collection, or release of a social security
number as required by state
or federal law.
The total impact of the new law on California
employers is still not
entirely clear because the law does not define
important terms such as
"application," "form," or "materials" sent by
mail, and "for internal
verification or administrative purposes." It is
also unclear whether the law
applies to ERISA-governed
benefits.
There is a safe harbor provision for employers who have
consistently and
continuously used employees' social security numbers in
a manner that
violates the newly-passed legislation. To qualify for the
safe harbor
provision the employer must:
Engage in the
non-conforming practice continuously and without interruption
(the law's
prohibitions automatically apply if the practices cease for any
reason);
Provide employees with an annual disclosure, beginning in 2002,
informing
the individual that he or she has the right to stop the use of
his or her
social security number in a manner prohibited by the statute;
Implement an individual's written request to stop the use of his or
her
social security number in a manner prohibited by the law within 30
days of
receipt of the request, and no fee or charge may be required
for
implementing the request; and
Not deny services to any individual
who makes a written request to stop the
use of his or her social security
number in a manner prohibited by statute.
The safe harbor provision may
not be of significant help for California
employers because employees can
opt out of non-conforming social security
number use any time after July
1, 2002.
We recommend that employers: (1) carefully examine their
uses of employee
social security numbers, (2) identify any non-conforming
practices, and (3)
consider modifying documents or delivery methods. We
note that the use of
social security numbers on the itemized statements
which must accompany
paychecks will remain unaffected since that use is
required by California
law.
Although the outlook remains unclear,
this attempt by the California
legislature to eradicate identity theft
and protect employee privacy will
impact many employers' current uses of
social security numbers.
Please contact John McLachlan if you would
like a complete copy of the new
legislation, have any questions, or wish
to discuss the matter further. He
can be reached at (510) 763-4411 or at
[EMAIL PROTECTED].
-----Original
Message-----
From: Christopher Feahr [mailto:[EMAIL PROTECTED]
Sent: Friday, September 19, 2003 1:12 PM
To: WEDI SNIP Transactions
Workgroup List
Subject: Re: Insurance cards with no Insured
ID
You're saying it's OK for payers in CA to continue using SSN
as the primary
means of identifying patients in their systems... but
that the SSN cannot
be printed on a wallet-card? So we CAN use the
numbers to identify people
but we must cease and desist the evil
practice of using paper cards to
identify people??
Does the law
prohibit only "wallet sized", ink-on-paper renderings? What
about
mag-stripe or bar-coded SSNs on wallet cards?
Bizarre...
At
12:15 PM 9/19/2003 -0400, William J. Kammerer wrote:
>I don't think
the California law bans using the SSN as an ID - just
>that it can't
be printed on an identification card. Since most
>everyone
knows his own SSN, that shouldn't be much of a handicap.
>
>If
Susan were able to "do" an electronic eligibility inquiry using the
>name and SSN, and perhaps the adddress, then surely that same
>information should be suitable for filing a claim, wouldn't you
think?
>
>William J. Kammerer
>Novannet,
LLC.
>Columbus, US-OH 43221-3859
>+1 (614)
487-0320
>
>
>----- Original Message -----
>From:
"Doug Webb" <[EMAIL PROTECTED]>
>To: "WEDI SNIP
Transactions Workgroup List"
><[EMAIL PROTECTED]>
>Sent:
Friday, September 19, 2003 11:47 AM
>Subject: Re: Insurance cards with
no Insured ID
>
>
>William,
>Mainly because of the
"I dunno" response from the insurance company.
>That indicates to me
that they have no idea what the proper ID is. If
>they had come
up with any positive response, working with them would
>be, indeed,
the better option.
>
>They're being a pain, and blaiming HIPAA
when the cause is California
>law banning the use of SSN as ID.
Sometimes, the only way to get some
>payers (most are great guys, but
a few...) to clean up their act is to
>apply pressure from the ones
who are actually paying them (the
>policyholders).
>
>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]
>
>
>
>
----- Original Message -----
> From: William J.
Kammerer
> To: WEDI SNIP Transactions Workgroup
List
> Sent: Friday, September 19, 2003 10:02
AM
> Subject: Re: Insurance cards with no Insured
ID
>
>
> Doug, why can't Susan file the
claim? The patient surely knows her
>own
>
SSN, so leave off the member ID on the Subscriber NM1, and include
a
> secondary reference to the SSN. Can't insurance
companies find out
>which
> subscriber (or patient)
is being referred to solely by the name and
>the
>
SSN? They have computers, don't they? Why put the patient in the
>middle
> of this?
>
>
William J. Kammerer
> Novannet, LLC.
>
Columbus, US-OH 43221-3859
> +1 (614)
487-0320
>
> ----- Original Message
-----
> From: "Doug Webb" <[EMAIL PROTECTED]>
> To:
"WEDI SNIP Transactions Workgroup List"
> <[EMAIL PROTECTED]>
>
Sent: Friday, 19 September, 2003 10:04 AM
> Subject: Re:
Insurance cards with no Insured ID
>
>
>
Susan,
> 1) Blaming HIPAA for this fiasco is totally
bogus.
>
> 2) "I dunno" is a totally unacceptable
response from the insurance
>
company.
>
> 3) If you can't get a vaild insurance
ID, you can't file a claim. A
>270
> query
MAY reval the proper information. You shouldn't have to do so
>to
> get a valid ID. Bill the patient.
Inform the the insurance company
> that you will do this,
and will give the patient X days to pay before
> being
referred to your collector. The insurance company will
probably
> respond "You can't do that!"; you can respond
"We can and will if you
> don't clean up your
act!"
>
> 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
> and/or legally privileged. It is intended
only for the use of the
> individual(s) and
entity(s) named as recipients in the message. If
>you
> are not an intended recipient of the
message, please notify the sender
> immediately,
delete the material from any computer, do not deliver,
>
distribute, or copy this message, and do not disclose its contents
or
> take action in reliance on the information it
contains. Thank
you."
>
>
>
> ----- Original
Message -----
> From: Susan
Hollabaugh
> To: WEDI SNIP Transactions
Workgroup List
> Sent: Friday, September 19,
2003 07:17 AM
> Subject: Insurance cards with
no Insured ID
>
>
>
> We have begun
receive patients in our California Imaging Centers who
>
present Insurance cards with no Insured ID.
>
> Here
is the experience as reported from our Director in the
region:
>
> "One Health Plan and Aetna are issuing
new insurance cards without the
> Insurance Identification
Number. I called both insurances to ask why,
> and was
told, "HIPAA". Both are in the process of issuing new cards
to
> ALL members
>
> So I asked,
the patient, "what is your Insurance ID number?". "I
>dunno"
> , was the
answer
>
> So I asked the insurance companies, "are
we to assume that the ID
>number
> is the social
security number?" "I dunno" , was the answer. They would
>
not provide me with the ID number."
>
> How are we
going to bill a patient's insurance company under these
>
circumstances? How are others dealing with this situation? Will
this
> necessitate Eligibility verification? Could we find
the information
>that
> we need that way? If this
extends throughout the market, it will be a
> nightmare
for providers.
>
> EDI Project
Manager
> 8754 Dunstable
Loop
> Bristow, VA
20136
>
>
>
>---
>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
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>If
you need to unsubscribe but your current email address is not the
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>as the address subscribed to the list, please use the
>Subscribe/Unsubscribe form at http://subscribe.wedi.org
Christopher
J. Feahr, O.D.
Optiserv Consulting (Vision Industry)
http://Optiserv.com
http://VisionDataStandard.org
Office
(707) 579-4984
Cell (707) 529-2268
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These listservs should not be used for
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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
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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
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The
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discussions on this listserv therefore represent the views of the individual
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question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/.
These listservs should not be used for commercial marketing purposes or
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