Chris
Your comment below assumes that the solution is an X12 solution, I was not
aware that X12 had made such a decision. I thought the purpose (as
articulated by everyone from the vision industry that attended the HL7
meeting in Jan) of the meeting sponsored by the AOA was to try and get your
collective arms around what the issues were, including what CMS's
interpretation might be, and then try and determine what the correct
technical solution was. As you will recall, HL7 and later X12 and NCPDP
all agreed to help the industry in hashing this out.
The feedback that I've gotten from X12N TG2 WG2 (claims) is that we aren't
there yet and that there haven't been decisions made regarding the use of
the claim for any part of the technical solution yet. I could have fallen
behind on the dialouge however. Has WG2 made the decision to use the FRM?
I would have thought this would have been a decision made in collaboration
with HL7 as putting "lists/ forms" of informaiton (what the FRM currently
does for DME CMN's) is essentially the same thing as providing the
attachment forms we develop in HL7. WG2 members will recall that the FRM
is slated for removal from the 837 once a migration of the DME information
is made to HL7 as an attachment (currently under development). The FRM was
only included for this purpose in the first place because there was no
attachment standard yet.
Maria
"Christopher J. Feahr, OD" <[EMAIL PROTECTED]> on 04/15/2002 07:38:22 PM
To: "Koller, Greg" <[EMAIL PROTECTED]>, [EMAIL PROTECTED], George
Kaye <[EMAIL PROTECTED]>, [EMAIL PROTECTED]
cc:
Subject: RE: Code Set effectivity compliance testing
Greg,
For what it's worth, I believe CMS representatives have been invited to an
American Optometric Association sponsored meeting next month for members of
the vision industry. It will be interesting to hear their thoughts on
this. The additional confusion we have around code sets for eyewear plans
has put our provider software community even further behind schedule.
In fact, returning to the "version control" thread for a minute... vision
CEs may well be faced with a MUCH more serious problem than possibly having
to support both a "version A" and "version B" of a standard for
awhile. Given the fundamental nature of our codeset problems, the version
required on 10-16-03 just, flat doesn't work. If a "version B" compromise
that DOES work for payors is identified...shepherded through the DSMO...
the NPRM process... etc. etc., it still might be years before we can even
use it on a voluntary basis... because it will still be technically
different from the current standard.... maybe not different enough to break
anyone else's adjudication system, but different enough to require the
receiver to "relax" his compliance checker rules.
Some sort of "Papal Dispensation" may be needed to permit the vision
industry to use a later (i.e., not-yet-required or not-yet-approved)
version of the standard, as soon as it can be considered "closed for
comment" within X12.
-Chris
At 08:50 PM 4/14/02 -0500, Koller, Greg wrote:
>Chris,
>
>I concur.
>
>Every time I meet with a provider they start looking like deer in the
>headlights when I try to explain this. Part of the problem is the number
of
>vendors out there consistently telling them they will be compliant. I am
>not so sure the vendors are far off with their understanding. Yet, we
>continue to see major payers that are not yet at the point of introducing
>anything. The all or nothing concept with HIPAA is going to be
devastating
>to these providers, because they do not understand the additional data
they
>will be required to collect.
>
>As a clearinghouse, we have advocated strongly for the staged approach.
>Start publishing elements that are required and setting timeframes for
them.
>I think the biggest step for most entities will be moving from a flat NSF
or
>HCFA to a Looping ANSI, 4010 but not compliant. Payers should be doing
that
>- NOW! Next, start asking for and setting timeframes for the required
>elements, specifically those that are readily available or relational to
>current data. Lastly, set timeframes for non-relational and
>optional/situational data that the payer will require. That basically
>brings us to compliance. This will not only start getting reasonable
efforts
>made towards compliance, but it will educate the providers on what is at
>hand as we go along. I think the perfect opportunity to make such a method
>viable would be to have CMS take the lead in such a program.
>
>Just a theory.
>
>Greg Koller
>Manager of Operations and Business Development
>United Wisconsin Proservices
>(414)226-5520
>[EMAIL PROTECTED]
>
>
>
> -----Original Message-----
>From: Christopher J. Feahr, OD [mailto:[EMAIL PROTECTED]]
>Sent: Saturday, April 13, 2002 1:07 PM
>To: [EMAIL PROTECTED]; George Kaye; [EMAIL PROTECTED]
>Subject: Re: Code Set effectivity compliance testing
>
>Kepa,
>Has there been any discussion of the mechanism (and where its funding
might
>come from) by which providers' software vendors can be EDUCATED regarding
>this critically important issue? I have not met a single Office
Management
>System vendor yet who understands that even if the X12 EDI messages are
not
>going to be flying right out of the doctor's software, the required data
>elements for populating an 837 DO have to be in there and WILL have to be
>packaged up and handed off at some point to a "translator engine/entity"
>for conversion to the standard. I doubt that more than 5% of the OMS
>vendor community gets it that NONE of the old claim standards map reliably
>and consistently to the new HIPAA standards, and that sending NSF and
"1500
>print images" to a clearinghouse is NOT going to be much help to the
>doctor. Unless CHs and payors are prepared to massively "relax" these
>standards for awhile, we will be looking at a 90% reject rate for claims
>from small providers. This global misunderstanding (they don't even know
>that they don't know) may explain why almost no software vendors or
doctors
>are coming to X12 meetings or asking questions about this... only a year
>before they are supposed to be in "testing mode".
>
>(And if you think the OMS community is out of the loop on TCS standards,
>try asking a few doctors what they know about this! I'm doing a primarily
>TCS-related HIPAA presentation to 50 or 60 eye doctors in N. Calif. next
>week and they are pretty excited about hearing this. To date, all doctors
>have heard/read about HIPAA is the Privacy Rule. They just assume that
>their OMS vendors are wiring the TCS stuff into their next system
upgrade.)
>
>Regards,
>Chris
>
>At 09:56 PM 4/8/02 -0600, Kepa Zubeldia wrote:
> >George,
> >
> >That is a very interesting point. Is your assumption that the
>clearinghouse
> >creates the transactions and has control of the code sets? The fact
that
>the
> >clearinghouse has demonstrated the "capability" to use a certain code
set
> >does not necessarily mean that each one of the providers clients of that
> >clearinghouse is using that same code set. I wish life was that easy.
> >
> >One of the typical "HIPAA Myths" is that the clearinghouses can
magically
> >make the providers compliant. That is not the case. Let's make sure
that
> >all the players understand what is their own responsibility. If the
> >expectations from providers are that their vendor or clearinghouse will
>take
> >care of HIPAA much like they took care of Y2K, we will run into big
>problems
> >when they wake up to the reality.
> >
> >Kepa
> >
> >
> >
> >
> >On Monday 08 April 2002 02:58 pm, George Kaye wrote:
> > > If a payer performs compliance testing with a clearinghouse for code
set
> > > effectivity for a professional claim (for example), has anyone
thought
> > > through the process of what that testing should consist of, so that
the
> > > payer can assume that those code sets will continue to be compliant
from
> > > that clearinghouse on an ongoing basis regardless of: the type of
> > > professional claim (office visit, ambulance, physical therapy etc.),
or
> > > when the code is impacted by new code set releases by the DSMO's?
> >
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>Christopher J. Feahr, OD
>http://visiondatastandard.org
>[EMAIL PROTECTED]
>Cell/Pager: 707-529-2268
>
>
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Christopher J. Feahr, OD
http://visiondatastandard.org
[EMAIL PROTECTED]
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