RE: Issue Mediation

[Julie Thompson]

Cynthia:

Thank you for your questions and comments.

First, let's clarify SNIP, DSMO, and HCCO roles.

SNIP is primarily a business implementation support group. This group makes not regulatory business practice recommendations.

DSMO are professional organizations given specific authority over certain components for the standards. They are responsible for defining, maintaining and updating the regulated standards.

SNIP addresses business practice issues.
DSMOs address transaction and code sets issues.

HCCO is not suggestion overlapping responsibilities at all, but filling a much needed gap in the implementation process.

Cynthia, you made a very important point...

"For any covered entity, rat-ing a trading partner out to CMS is an extreme measure to take, especially if all a covered entity wants to do is avoid being pulled in multiple directions by multiple trading partners as details of hipaa transaction conformance are ironed out."

HCCO will be the front end process allowing our members to hash out any transaction issues prior to elevating the problem to CMS.

All stakeholders will be very relieved to find a much needed (and unfulfilled) service to the industry.

THANKS, let's be careful out there :-)

Julie A. Thompson
Executive Steering Commitee, HCCO
Vice President, Concio





From: "Mark A Lott" <[EMAIL PROTECTED]>
Reply-To: "WEDI SNIP Testing Subworkgroup List" <[EMAIL PROTECTED]>
To: "WEDI SNIP Testing Subworkgroup List" <[EMAIL PROTECTED]>
Subject: RE: Issue Mediation
Date: Sat, 7 Dec 2002 01:42:34 -0700

Cynthia,

Thank you for the excellent suggestions. I would like to clear up a few
issues though.

First is that a message of this type should be posted on the HCCO listserves
instead of here. I don't think it is fair that HCCO discussions take place
on WEDI listserves when the subject is mainly concerned with our processes.
I would ask everyone that future messages focusing on HCCO not be posted
here. Here is a response to your suggestions.

Second, the mediation process for which you refer is a service to our
membership as a way to resolve issues among members not intended to
interfere with established mechanisms already in place. It is not really
meant as a "whistle blower" process instead it is a way for organizations to
discuss solutions before they become major problems and as a sponsor
organization, it is a required element that would be part of our role.

Transactions, Privacy and Security will have different protocols. For
instance, Transactions will follow the ANSI Conformance Certification
Program, Privacy will be decided shortly and Security must certainly follow
an already accepted industry standard because Security requires
certification. Mediation and arbitration are integral parts of the programs
and the responsibility of the sponsoring organization. It is a mandatory
element of any program that sponsors and accredits third party certifiers
(which answers the age old question of who certified the certifier) and
watches over them to ensure the quality of their programs and must get
involved in case of disputes, that is the reference here of mediation as
well as upcoming concerns with interoperability of multiple infrastructures.
This is exactly how ISO, ANSI, UCC, etc all function in every other
industry, these programs are not involved in HIPAA so we thought we would
invite them in!

It all comes down to the notion that healthcare is undergoing drastic
changes in all practice areas and it is extremely pragmatic to not re-create
the wheel but instead use industry proven solutions and methodologies to
ensure conformance and especially business continuity of all the
organizations involved in implementing HIPAA.

SNIP is named in the legislation today but I thought it was meant as
education. Honestly I never envisioned WEDI taking on the role as a
sponsoring and accrediting agency, am I wrong? I thought they just issue
recommendations? Can someone fill in the gaps for me here? As far as HCCO
members serving on WEDI workgroups, that happens already. Actually most of
the HCCO membership was part of WEDI, SHARP, MAHI, etc., well before we
began and they continue to serve multiple roles as well. I think it is a
great testament to the volunteerism of so many thoughtful and dedicated
people we have in this industry, without it HIPAA implementation would be a
much greater challenge if not impossible.

Regards,

Mark A Lott
President/CEO
HIPAA Testing, Inc.
www.hipaatesting.com

Executive Co-Chair HCCO - Transactions Group
HIPAA Conformance Certification Organization
www.hcco.us

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-----Original Message-----
From: Cynthia Korman [mailto:[EMAIL PROTECTED]]
Sent: Friday, December 06, 2002 11:33 PM
To: WEDI SNIP Testing Subworkgroup List
Cc: Mark Lott
Subject: Issue Mediation

Hi Julie - re: education and mediation services that HCCO might offer, I
hear you re: the appropriateness/importance of providing such a service.
For any covered entity, rat-ing a trading partner out to CMS is an extreme
measure to take, especially if all a covered entity wants to do is avoid
being pulled in multiple directions by multiple trading partners as details
of hipaa transaction conformance are ironed out.

I firmly believe that this mediation process must meet the following
standards:
1) It must integrate the HIPAA-mandated DSMO Change Request system
http://www.hipaa-dsmo.org/crs/, and respect the change request dispositions
made through that system since those decisions carry the force of law
2) It must provide feedback to the DSMOs (X12/HL7/NCPDP)
3) Its recommendations must be made open to the public (easily done through
submission of DSMO Change Requests)
If it doesn't meet these standards, how can the mediation process avoid
creating shadow standards?

Regarding your comment that HCCO will act as a completely neutral third
party whose goal is the achieve
compliance with the standard and maintain the cost savings/reduction
originally planned in the legislation through the implementation of a single
transaction standard for all covered entities - How does that differ from
SNIP's mandate?

If HCCO and SNIP tackle this independently, for each issue one of two things
will happen
1) Great minds will think alike and a single resolution will be
independently developed.
2) Intelligent people will differ, and when they come together through the
DSMO process to debate their differences, the more rational argument will
win. (as long as enough folks are willing to give their time to participate
on the mediation committees!)

Because the HIPAA legislation gives issue resolution authority to SNIP and
the DSMOs, I think the HCCO folks who would be willing to take on mediation
responsibility would be best advised to work instead through SNIP, since in
the end SNIP will have the force of law. What's stopping HCCO'ers from
chairing SNIP subcommittees? I know the SNIP Business Issues committee,
which considers and resolves some of the DSMO CRS-captured issues, had
committee chair positions open not too long ago - I don't know whether or
not they've been filled...

Best wishes!

Cynthia Korman
[EMAIL PROTECTED]

----- Original Message -----
From: "Julie Thompson" <[EMAIL PROTECTED]>
To: "WEDI SNIP Testing Subworkgroup List" <[EMAIL PROTECTED]>
Sent: Thursday, December 05, 2002 2:06 PM
Subject: RE: HCCO Value Proposition


> Correct other email dialogue offer the the FAQ in which CMS stated:
>
> CMS FAQ: How would someone file a complaint against a covered entity?
> CMS will develop a web-based complaint management process, and will
provide
> information on this process as part of our HIPAA outreach activities.
>
> As a part of HCCO due diligence to serve its members, we will offer
> education and mediation services which go beyond Medicaid and Medicare
> requirements.
>
> PLEASE, PLEASE DO NOT INTERPRET THIS AS THE HIPAA POLICE!
>
> This is purely, clearly intended to be a front line anonymous arbitration
> effort for our members. Many HCOs are unwilling to get directly involved
in
> trading partner issues. The relationships are too important!
>
> HCCO will act as a completely nuetral third party whose goal is the
achieve
> compliance with the standard and maintain the cost savings/reduction
> originally planned in the legislation through the implementation of a
single
> transaction standard for all covered entities.
>
> All is favor, Say "I"!
>
> THANKS!
>
> Julie A. Thompson
>
>
>
>
>
>
> From: "Rachel Foerster" <[EMAIL PROTECTED]>
> Reply-To: "WEDI SNIP Testing Subworkgroup List"
> <[EMAIL PROTECTED]>
> To: "WEDI SNIP Testing Subworkgroup List" <[EMAIL PROTECTED]>
> Subject: RE: HCCO Value Propistion
> Date: Thu, 5 Dec 2002 11:07:27 -0600
>
> I believe such an organization already exists - WEDi SNIP. Post 10/16/03
> complaints regarding non-compliance should be directed to the CMS
> enforcement arm headed up by Jared Adair.
>
> Rachel Foerster
>
> -----Original Message-----
> From: Julie Thompson [mailto:[EMAIL PROTECTED]]
> Sent: Wednesday, December 04, 2002 3:50 PM
> To: WEDI SNIP Testing Subworkgroup List
> Subject: HCCO Value Propistion
>
>
> I am working on several client implementations. There major concern is
lack
> of compliance (or none at all) from their trading partners.
>
> They do not want to cause a problem with their payors.
>
> What if there was an organization who they could report their concerns to,
> and this organization would act as a first level of education and/or
> mediation???"?
>
> Julie
>
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discussions on this listserv therefore represent the views of the individual
participants, and do not necessarily represent the views of the WEDI Board
of Directors nor WEDI SNIP. If you wish to receive an official opinion, post
your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/. These listservs should not be used for
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disagreements or unprofessional communication at any time.

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