RE: Who Pays for Compliance Testing?

[David Blasi]

We are approaching testing from two angles and I think this might be helpful for the discussion:   1.  The testing we will do internally, with a key trading partner, or with a testing entity such as Claredi, to document that we believe we can accept and transmit all required standards.  The results will be used to report to our compliance committee, as well as to make public representations.    2.  The testing that is requested from any entity who has an interest in our organization's abilities, but such testing does not impact our own analysis.  Otherwise known as the category of "Prove that you can do this with me".   In the first category, we will obviously incur our own testing costs and would expect to pay for our own outside testing.  With key trading partners (vendors, clearinghouses only), this will depend on current contract terms or future negotiated terms.  The question to ask in determining if the testing falls into category 1 is, "Do I need to do this testing with the other organization to ensure my organization can process HIPAA transactions?"  If the answer is "Yes", you should probably pay.  If the answer is "We both do", share the costs.  If the answer is "No", falls into second category.     For the second category we would treat this like an external audit.  We have no internal need or desire to do this testing, therefore, the requestor is responsible for all costs of the audit.  We can control the extent of the audit, including stating that if you want to test, you need to go to an entity like Claredi.          >>> "Ajay K sanghi" <[EMAIL PROTECTED]> 10/31/01 10:57PM >>> In my mind each entities should pay for compliance of the messages they "send", even though the real benefit lies with the entity who receives the message. I don't think that compliance testing has to be done "specific" to each trading partner relationship. I agree with what Robert Barclay writes: >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. Ajay -----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]]On Behalf Of Christopher J. Feahr, OD Sent: Thursday, November 01, 2001 2:13 AM To: Robert Barclay; [EMAIL PROTECTED] Cc: Craig Steele Subject: Re: Who Pays for Compliance Testing? I have not seen a "rule" on this, but it seems that each covered entity would be obligated to undertake (and pay for) whatever testing it deemed necessary. If a big entity wants to "mandate" that all of its trading partners pass at a certain testing level with a particular certifying agency (probably a good idea), then the requesting/requiring party should probably pay.  This would be similar to the concept used in deciding which party pays for a clearinghouse transaction... the one "requiring" the service. Regards, Chris At 11:45 AM 10/31/01 -0600, Robert Barclay wrote: >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 > > > >********************************************************************** >To be removed from this list, send a message to: [EMAIL PROTECTED] >Please note that it may take up to 72 hours to process your request. Christopher J. Feahr, OD http://visiondatastandard.org [EMAIL PROTECTED] Cell/Pager: 707-529-2268 ********************************************************************** To be removed from this list, send a message to: [EMAIL PROTECTED] Please note that it may take up to 72 hours to process your request. ********************************************************************** To be removed from this list, send a message to: [EMAIL PROTECTED] Please note that it may take up to 72 hours to process your request. ********************************************************************** To be removed from this list, send a message to: [EMAIL PROTECTED] Please note that it may take up to 72 hours to process your request.