The responds to my earlier compliance testing queries and a current discussion on the Transaction listserv brought up more questions in my mind. I am curious of how others view these items. The items are: Testing time, the role of Medicare, and acceptance of non-compliant transaction.
1. Testing Time. I made a couple calls to EDI shops to find out the current time required to test a new trading partner. The answer ran from 10 to 80 hours for each trading partner with the average running somewhere in the lower middle. These are for complete testing, equivalent to HIPAA levels 1 through 6 plus payer specific testing. Some clearinghouses were retested each time a new provider was added while other clearinghouses were give card blanche. Does this mean payers will spend 30 +/- hours doing level 1 - 6 + testing for each HIPAA trading partner by October 16? That is a lot of hours and a significant staff requirement. What are others anticipating for testing time? If a third party testing service, Claredi or Foresight, is used what testing time savings can be anticipated? In other words, how long will it take to just test for payer specific needs if a third party performs the HIPAA testing? 2. The Role of Medicare. The Medicare fiscal intermediaries are, in effect, agents of the HIPAA enforcement authority, CMS (formerly HCFA.) If a submitter obtains approval from one or more Medicare payers for their transactions why should anyone else need to compliance test them? What happens if Medicare payers' definition of compliance varies from those in the X12N school? Which approval counts, the kid whose dad is the police chief or the kid with the encyclopedia? Additionally, CMS is asking the Medicare payers to be ready to start testing early. This means for many claims submitters, Medicare will be their first HIPAA transaction test. Should other payers just follow Medicare's lead and assume that Medicare approved submitters are compliant? Do payers want to retest for compliance and potentially conflict with Medicare? If payers wait for Medicare to test their trading partners when will they be done? 3. Acceptance of Non-compliant Transactions. What happens if a payer, or provider for that matter, receives a non-compliant transaction but does not detect it up front? Either because the non-compliant value is taken into the processing system and then rejected (i.e. a local code) or the value is ignored from the start. There is no intent to violate the HIPAA rule, just a technical limitation of the receivers processing system. If I understand the intent of rejecting non-compliant transaction, it is to shot backroom agreements to go beyond the IG. Will CMS pursue parties accepting non-compliant transactions that receive no advantage from the "illicit" data? I doubt it. To take this argument a step further, why should we compliance test for levels 1 through 6 if we only care about levels 1, 2, 4, and 6 at the translator level? Why should I test my trading partner's ability to count segments correctly if I never use that value in my processing? Why do I need to test for valid CPT4 codes in the translator if I already do that in my claims processing system? My head is starting to hurt and the clock is still ticking. Comments for any brave souls? 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.
