Fortunately, we're not burdened in this sub working group with having to answer the question whether individual trading partner agreements are required to be executed by each possible provider-payer pair. But it is definitely an interesting discussion, so I'm looking forward to seeing more of it - and its resolution - on the general Business Issues listserve!
Certainly, HIPAA itself doesn't mandate TPAs, does it? Because, surely, that would be an impediment to "administrative simplification" - it would just be simpler to send paper claims where the volume doesn't justify the horrendous costs of executing a pairwise agreement. Ronald Bowron quoted a snippet out of the final rule: "we interpret HIPAA to mean that a health plan cannot refuse to conduct a transaction because it is a standard transaction, ....." A payer requiring an onerously expensive TPA ($50??!! -that's a bigger money making racket than the residential real estate appraisal business) before it accepts a standard transaction could be construed as "refusal," couldn't it? Why would an electronic claim need to be covered by a TPA when a paper claim (containing the same information) wouldn't? - is it because each electronic transaction would be missing the "signature," as if doctors really sign these things themselves? As Rachel has said, "[if] HIPAA will end up forcing agreements between each provider and its payers, then the questions about who should be identified on the ISA becomes moot." There would be no point in us spending our time figuring out automated ways to share trading partner information (such as electronic addresses) if paper TPAs were required: this information (the ISA Identifiers and the electronic addresses) could just be placed on the same (expensive) piece of paper. William J. Kammerer Novannet, LLC. +1 (614) 487-0320 ----- Original Message ----- From: "Rachel Foerster" <[EMAIL PROTECTED]> To: "WEDi SNIP 4 (E-mail 3)" <[EMAIL PROTECTED]> Sent: Monday, 28 January, 2002 12:55 PM Subject: FW: TPA's -----Original Message----- From: Marcallee Jackson [mailto:[EMAIL PROTECTED]] Sent: Saturday, January 26, 2002 8:21 AM To: [EMAIL PROTECTED] Subject: re: TPA's I'll be bringing the issues of TPA's back to the BI work group. I hope the group will choose to address this topic ASAP. Payer to provider TPA's, required even when there is no direct connectivity between the two, will cause the labor costs associated with EDI enrollment to sky rocket. I'm certain that payers who do not require this today (and the vast majority of payers do not) will incur very significant costs to develop and support the process. Clearinghouses most often facilitate this process by managing forms distribution, provider support, routing agreements to the payer, follow-up and approval notification. Today, providers using a clearinghouse must complete enrollment paper work (TPA's) for 3 or 4 payers. If this number jumps to 25 or 30 a clearinghouse could see its enrollment costs as much as tripling. Eventually, this cost will likely be passed on to the provider who will add new fees to their own internal costs of completing 25 - 30 proprietary agreements. Already one vendor who has an exclusive agreement with one clearinghouse has begun to charge $50 per physician per agreement. For one of my clients, the total charge was over $8,000. This enrollment process is also one of the greatest obstacles to a swift implementation. Most Medicare and Medicaid plans take 6 to 8 weeks to complete the process. That's after the clearinghouse spends 4 - 6 weeks getting completed paper work from the provider. How many weeks will it take when every payer asks for a TPA? I'm looking forward to working with other SNIP participants to find a better way to handle this. Marcallee Jackson Long Beach, CA 562-438-6613
