This is an excellent discussion so I'm going to include the folks on
HIPAALive.

In terms of CE's who use clearinghouses, if the CE is looking to the
clearinghouse for translation I think it should be looking for a test of
the translation of their non-standard to the standard and a report back
on the success of that test.  Depending on the extent to which the
translation is not successful, there could be quite a bit of work to be
done.  If the worse case scenario were to occur (translation to the
standard is not possible using the current non-standard format), the CE
would want to know that ASAP.  

Though perhaps not a requirement for the April deadline, if the
clearinghouse returns successful test results, the CE might want those
results tested for compliance yet again by a neutral third party testing
system.  

Marcallee Jackson
Long Beach, CA
562-438-6613

-----Original Message-----
From: Cynthia Korman [mailto:ckorman@;healthcare-systems.com] 
Sent: Wednesday, November 06, 2002 7:35 AM
To: WEDI SNIP Testing Subworkgroup List
Subject: Fw: "Testing" defined for 4/03 deadline?

Following is from the HHS HIPAA FAQs web site (today)

"Question: Section D of the ASCA compliance extension form specifies a
timeframe for testing not later than April 16, 2003. Can you provide a
definition of testing, and does it relate to all transactions?"

"Answer: ASCA requires that testing begin no later than April 2003. The
law
itself did not specify what type of testing, (e.g. internal,
external,final
with trading partners, all transactions, or just one, etc.) HHS
interprets
this to mean the date requested on the extension form as the date when
internal system testing begins for the first transaction the covered
entity
will test. However, some covered entities will need to begin their
external
testing sooner than others, especially those that have many trading
partners or are implementing many of the transactions. We encourage all
covered entities to begin testing as soon as possible."

Now, for covered entities, what does "internal testing" mean?

A1) Starting work toward certifying transactions, before trading partner
testing, perhaps through business associates?  But, from the specific
covered-entity's perspective, using THAT covered entity's data?
A2) Confirming that business associates (software vendors and, for
providers and payors, clearinghouses) have started testing?   If so, how
much detail should the specific CE be getting?
A3) On 4/16/03, having hipaa-ready software installed and ready for
testing
new data capture and generation of hipaa-compliant transactions?
A4) For the DDE exception, being scheduled with the trading partners to
test hipaa-compliant DDE?

 What have I missed?

- Cynthia




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