Rachel,

It goes back much further.  On May 7, 1998, the transactions PROPOSED rule 
says (Page 25297) the following:

   A. Compliance Testing.
   We have identified three levels of testing that must be 
   addressed in connection with the adoption and implementation
   of the standards we are proposing and their required code sets:
   Level 1 -- Developmental testing -- This is the testing done by
   the standards setting organization during the development
   process.  [more text, omitted for brevity]
   Level 2 -- Validation Testing -- This is testing of sample
   transactions to see whether they are being written correctly.
   We expect that private industry will provide commercial testing
   at this level.  This level of testing would give participants a
   sense of whether they are meeting technical specifications
   of structure and syntax for a transaction, but it may not
   necessarily test for valid data.  This type of testing would
   inform individuals that the transaction probably meets the
   specifications.  These edits would be less rigorous than
   those that might be applied by a health plan before payment
   (in the case of a claim) or by a health care provider prior
   to posting (in the case of a health care claim payment/advice).
   The test conditions and results from this level are generally 
   shared only between the parties involved.
   Level 3 -- Production Testing -- This tests a transaction 
   from a sender through the receiver's system.  The test
   information is exposed to all of the edits, lookups, and
   checks that the transaction would undergo in a production
   situation.  The test conditions and results from this level are
   generally shared only between the parties involved.

The proposed rule continues discussing the desirability for "pilot production" 
projects, with results posted on a web site.  Then the proposed rule, in the 
next section, solicits input from the industry thusly:

   We are at this time, however, soliciting input on appropriate
   mechanisms to permit independent assessment of compliance.
   We are particularly interested in input from those engaging in
   health care EDI as well as from independent certification and
   auditing organizations addressing issues of documentary
   evidence of steps taken for compliance; need for/desirability
   of independent verification, validation, and testing of systems
   changes; and certifications required for off-the-shelf products
   used to meet the requirements of this regulation.

One of the reasons for this particular text was because earlier that year, in 
the spring of 1998, EHNAC had announced the creation of the STFCS service: 
Standard Transaction Format Compliance System.  The EHNAC had been working on 
this system for a couple of years prior to the 1998 announcement.  The 
government was trying to get some industry feedback on this concept.  And 
they did get some feedback during the NPRM.  As a result of this, the Final 
Rule on Transactions published August 17, 2000, says on page 50342 under 
"Comments and Responses on Compliance Testing" the following:

   Several commenters suggested that all HIPAA standards
   projects be posted and that the government should provide
   funding or at least publicly advertise the results of all compliance
   testing projects.  It was suggested that the Electronic Healthcare
   Network Accreditation Commission (EHNAC) could host a bulletin
   board or web site in which tests results could be published.

   Several commenters asked whether entities providing
   validation testing will need to be certified.  They stated that
   validation testing is only useful if certification is obtained.
   Several commenters recommended that the Secretary endorse
   the Standard Transaction Format Compliance System (STFCS)
   process established by EHNAC for validation testing, suggesting
   that EHNAC certification lends credibility and reliability to the
   process.  However, other commenters wanted certification for
   compliance to be voluntary.

   Several commenters recommended that WEDI, X12, or some
   other group further develop the various types of testing situations
   which might occur as well as tentative protocols for handling
   such tests.
   [ more text omitted for brevity.]

   Response: We agree that posting of results for any HIPAA
   standard should be voluntary.  As long as the transactions are
   successfully implemented in production, posting of the results
   is more of a marketing, advertising, and sales issue than a 
   technical concern.

   Since the HIPAA provisions do not require the Secretary to
   certify compliance with HIPAA standards, the Secretary is not 
   conducting certification reviews or recognizing private
   organizations that have decided to conduct such reviews.
   Therefore, any certification of commercial entities performing
   validation testing will remain in the private domain and be
   voluntary.  While receivers of transactions are likely to test
   whether a vendor that claims to be HIPAA compliant is, in fact,
   producing compliant transactions, this is a matter of business
   practice, and such tests are not being mandated in this rule.

Following the spirit of this regulatory text, and the recommendations of 
commenters to the NPRM, when SNIP was formed, one of the workgroups took the 
task of writing a white paper on testing and certification.  This white paper 
was led by Dave Moertel (Mayo Foundation) and Mark McLauglin (McKesson/HBOC) 
and the very first draft of this paper already had the first 5 "levels" of 
testing.

In the Fall of 2000, the sixth level was added.  This was my first 
contribution to the white paper, so I know it first hand.  At the time I was 
still working for Envoy.  In my past 18 years working with (leading, rather) 
clearinghouses, I had run into numerous testing problems that were specific 
to different specialties and unique to different lines of business, so 
testing for these unique conditions was a requirement of any test 
environment.  At Synaptek (pre-Envoy) we had developed a testing process that 
allowed us to test, very effectively, the EDI files from tens of thousands of 
providers and payers that came to our clearinghouse.

It seems that if we ignore the history, we end up repeating the same things 
over and over.  So, I hope this historical summary helps us to not waste much 
time reinventing these wheels.

Kepa Zubeldia
Claredi




On Saturday 21 December 2002 09:27 am, Rachel Foerster wrote:
> I'm getting real tired and annoyed of the comments that suggest the concept
> of certification is an attempt by some to steal market share, emanate from
> some hidden agenda, etc. It simply is just NOT true. The origin of the
> concept of certification was written into the white paper in mid-2000 and is
> a concept that came out of AFEHCT, WEDI, and EHNAC in 1997 or earlier, long
> before the current vendors were involved in HIPAA transaction testing.  It
> came out of a search for a solution to the mass deployment of testing
> problem that was, and is, looming in the HIPAA future."
> 
> Now...can we please move off this non-productive discussion and get on to
> developing a consensus statement/definition of the concept of certification
> that will be useful to the industry during this extremely challenging stage
> of actually implementing the HIPAA EDI transaction sets?
> 
> Rachel Foerster


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