Who should pay for compliance testing, the transaction sender or the transaction 
receiver?  This assumes, of course, that a third party is performing the testing.  
Both parties have legal and practical interests in insuring the exchanged transactions 
are compliant.  

It would appear the first level of responsibility lies with the creator of the file.  
They must create a compliant transaction.  The receiver of the transaction just needs 
to identify compliance and reject it if non-compliant.  In practice, however, payers 
in the claims world have a vested interest in getting clean test 837 transactions.  
Large payers have hundreds or thousands of claims trading partners to test by October 
16.    Compliance testing should clean up all but exchange management and adjudication 
optimization testing issues for payers. 

So, once more who should pay for compliance testing?   Kepa, or other smart people, 
would you care to comment?



Robert Barclay
EDS - Wisconsin Medicaid HIPAA Team
[EMAIL PROTECTED] 
(608) 221-4746 x3323



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