Y'All,
This is what I got down from today's BI conference call
regarding the Issues Data Base (IDB). If I have any of this down wrong, or
if you have any additional information on any of these issues or any of the
other IDB items, please send your comments to Marcallee. The
link to Marcallee's table is http://snip.wedi.org/public/restricted/articles/SNIPIssuesthru04-29-02.doc.
- Zon -
Marcallee,
As usual, there wasn't a lot of input. But what we
received should be quite useful.
#???: Claudia Faulkner participates in the X12N 278 WG,
and volunteered to check on this and try to provide an answer.
#099: This would seem to be a general business
continuity issue that would fall under the Security rule, rather than the
TCS rule. It is surely a good business practice to design your operations
to be fault tolerant, so that you can repeat a process as needed.
#105: This should probably be discussed with X12N TG2
WG2 (Claims). If Stuart does not like their explanation, he should submit
a DSMO request.
#106: You shouldn't need two 2300's for this. We
need to refer it to X12N TG2 WG2.
#120: We also need to refer this to X12N TG2 WG2.
It is my impression that the original intent was to permit the use of the HCPCS
codes for OP claims, but not to require their use for all OP claims. But
the IG may not say that.
#121: What they say sounds reasonable, but HHS would
have to confirm that. Peter Barry volunteered to research
this.
#127: Peter Barry volunteered to research this. My
own guess is that a compliant transaction generated by this vendor's software
would be a compliant transaction, but that providers could not be required to
use that specific software. I.e., the payer would still have to accept
compliant transactions generated by pother means directly of via a
clearinghouse. So the answer is "Yes" and "No".
#159: The TCS rule preempts any state requirements that
are incompatible with it. Within the 835 they would be limited to the
Claim Adjustment Reason Codes and the Claim Remark Codes. If they felt
that they needed anything else, they would need to discuss that with the Code
Maintenance Committee. It might help to contact the submitter to determine
if we have captured all the nuances of her question. Proprietary codes
could presumably still be used on hardcopy documents.
#108: Change "o f a" to "of a" in the first line of
"Description".
#102: Change "DISA WG10" to "X12N TG2 WG10" in the first
line of the "Recommendation".
#104: Change "There the guide is not specific the" to
"Where the guide is not specific, the" in the second line of the
"Recommendation".
#126: The first line of the "Recommendation" should say
"in the 278", and not "in the 827. But, as nearly as I can tell, this
section did not get updated after our 04/16 discussion. At that time we
seemed to agree that the 275 could be used in this situation. Stanley
suggested that it would be OK as long as the guide (including the addenda)
explained that that was acceptable. Claudia Faulkner thinks that Greg
Gehmnan sent you some additional information on this.
#112: I would argue that the definition of a transaction
is amended by the definitions of the individual transitions. Thus, this
would not be decided by the definition of an entity, but by the definition of
the individual transaction. Peter argues that the TCS coveredness is
role-based, and that no entity is covered when it is acting in the role of an
employer. I would prefer that it was seen that way, but there is some
indication that HHS doesn't. Peter and I may trade e-mails on this and get
back to you later. This also affects our discussions with Don Bechtel, of
course. Unfortunately, Stanley wasn't on the call today, so I didn't get a
chance to run this by him.
"Status / Assigned To" Column: I would suggest that we
say "HHS Review", rather than "CMS Review", since HIPAA is the responsibility of
the Secretary of HHS, not of CMS. Also, if we are going to list these
items by Issue Number within Status, I suggest that we move the status column to
the left edge. I.e., organize the columns to follow the sort
sequence.
- Zon Owen -
(808)597-8493
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