I keep seeing implications that the 835 is somehow special - or as
"Church Lady" would say: "SPATIAL." Bob Poiesz has reminded us that
"all of the HIPAA transactions to date except the 835 are provider
initiated." That's a difference, but something that can be handily
accommodated in our "directory."
It's only fair that the provider advertise her capabilities, just as the
payer would. The provider's "directory" entry would say she's willing
and able to take 835 electronic Remittance Advices. It could also have
a notation that said she was willing to take electronic funds transfer
at her bank, specifying an ABA routing code and her account number. Of
course, the payer doesn't have to do EFT (even if he does do the 835
ERA), so this is optional on the part of the payer - but paper checks
mailed to the billing provider are still always welcome!
A monkey wrench will be thrown into the whole works if now every
provider and payer pair has to negotiate a TPA to do 835s. As Rachel
has correctly reminded us, TPAs are a barrier to establishing EDI
information exchanges. Other than telling a payer that she'd be willing
and happy to take EFTs, why would a provider have to establish a
contract to do so? EFTs to deposit money in someone else's account
(most likely at other banks) are a completely separate issue between the
payer and his bank - a relationship probably established long before
HIPAA. The provider doesn't have to grant "permission" to the payer (or
even any bank) in order for payers to throw money at her.
Perhaps some of the perceived "specialness" of the 835 is the conflation
of payment with remittance. The 835 seems to have been designed to
mimic the old paper remittance, which included the check under a
perforation. This document paradigm has been carried over to the
electronic arena. A payment (check or EFT) is an order to one's own
bank, with whom you already have a relationship. The payee has no
(necessary) relationship with the payer's bank, and doesn't need one in
order to demand her funds - through her bank or directly at the payer's
bank ("on-us").
The remittance, on the other hand, explaining the payment (and
containing PHI), is none of any bank's business - payer's or payee's.
Why the two - the ERA and dollars - should travel together is beyond me,
unless to slavishly mimic the paper remittance. And for banks to
advertise themselves as "Value Added Banks."
I can already see Chris Feahr, pulling himself away from installing new
lights, coding up Javascript to parse his incoming ERAs. If he has to
negotiate a TPA with each payer, that's going to put a demotivating
crimp in his automation endeavors.
William J. Kammerer
Novannet, LLC.
+1 (614) 487-0320
----- Original Message -----
From: "Christopher J. Feahr, OD" <[EMAIL PROTECTED]>
To: <[EMAIL PROTECTED]>
Sent: Tuesday, 12 February, 2002 10:00 PM
Subject: auto-discovery of the "return path" (In the Kepa-DNS model)
Speaking of semantics, we should figure out a standard term for the DNS
model that Kepa has suggested.
Anyway, in that model, if a "small provider" (also needs a definition!)
is able to send a claim (or anything) directly to a payor using the
health plan's "smart EDI address"... will this automatically mean that
the payor will be able to discover the address/route back to the
provider for 271s, 824s, etc.? (I assume that the 835 will require
special handling in a provider-payor agreement)
Does the provider's EDI address automatically get entered into the "DNS
table" in this proposed model?
-Chris
Christopher J. Feahr, OD
http://visiondatastandard.org
[EMAIL PROTECTED]
Cell/Pager: 707-529-2268
