This is getting slightly off the subject but just a quick answer to William's comments regarding my comments. I think it is clear congress intended to do what the healthcare industry was slow to do which was to automate and standardize to reduce costs along with the security and privacy issues. There is plenty of precedence of congress delegating rule writing authority to federal agencies constitutional or not. Regards,
David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 425-260-5030 -----Original Message----- From: William J. Kammerer [mailto:[EMAIL PROTECTED]] Sent: Tuesday, February 19, 2002 6:55 AM To: WEDi/SNIP ID & Routing Subject: Re: Number of IDs assigned to a provider: Time-out for scope Chris Feahr agrees that "the core problem being considered by our group is the addressing/routing of transactions." But he still wants to keep general discussion of identifiers open, and not just in the context of the ISA sender and receiver fields. I do think we will have to at least pay lip service to aspects of identifiers as they're used in the application transaction set - if only because applications will have to divine an ISA receiver ID from something, and that something will be the various combinations of IDs used today (within the application or the 837, say). For example, to do routing, a payer might need some way to find the provider's DUNS, HIN or EIN - one of the ID domains allowed by the HIPAA IGs in the ISA. We can't say you can key on any combination of criteria (including plans, contracts and line of business) to search for a (payer's) EDI address: a VAN or EDIINT software, which don't burrow into the application transaction, wouldn't have anything but the ISA receiver ID (and possibly some stuff at the GS) for making routing decisions. So keys used (as nodes) in Kepa's DNS "directory" would necessarily be restricted to ISA and GS information. Speculation and discussion on the National provider and health plan identifiers would best be left to the general Business Issues SWG. It doesn't do justice to such an important topic to confine it to our small area. After all, even if we had brilliant solutions to IDs in general, who would think of looking in a subsidiary white paper of the AFEHCT-WEDI Health Care Communications Security and Interoperability project for an answer? Given the amount of interest in the broader questions of Identifiers, would it be premature to call for a new Sub (or is it Sub-Sub?) Working Group under Business Issues to tackle this? - a sister group to ours, in effect? Kepa's Identifier myths and Chris Feahr's excellent observations on the "plan" and "line of business" (and their possible accommodation within the SBR segment) deserve a first-class forum for discussion and investigation. As a matter of fact, there's a Business Issues teleconference today at 3:30 EST; the telephone number is 703-736-7290, access code 1315330. That might be an ideal opportunity for me to bring up this issue. Please join in, if you can. As an aside, Dave Frenkel told Kepa he thinks "you are seeing Congressional intent clashing with reality [w.r.t. National Plan and provider IDs]." Is there Congressional "intent"? Congress has (some would maintain unconstitutionally) delegated its authority to a federal bureaucracy: HIPAA is not just a good idea - it *might* even be the law. William J. Kammerer Novannet, LLC. +1 (614) 487-0320 ----- Original Message ----- From: "David Frenkel" <[EMAIL PROTECTED]> To: <[EMAIL PROTECTED]> Sent: Tuesday, 19 February, 2002 01:33 AM Subject: RE: Number of IDs assigned to a provider: Time-out for scope I think you are seeing Congressional intent clashing with reality. It is not talked about too much fraud was one of the many issues in the early discussions concerning HIPAA legislation. It was thought if providers had a unique id it would be easier to find patterns of abuse. The reality being the need for plan ids given how the healthcare system currently works. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 425-260-5030 -----Original Message----- From: Kepa Zubeldia [mailto:[EMAIL PROTECTED]] Sent: Monday, February 18, 2002 8:45 PM To: [EMAIL PROTECTED] Cc: William J. Kammerer; 'WEDi/SNIP ID & Routing' Subject: Re: Number of IDs assigned to a provider: Time-out for scope Chris, For several years HCFA had been working on "payerID". Then HIPAA specified Plan ID in the law. That is one of the reasons why the regulations have not come out yet. It took a while to figure out how the Plan ID, which is what the HIPAA law specifies, relates to the payerID, which is what everybody wants. Kepa