Brian, I believe you're correct about complaints submitted now not being even looked 
at let alone addressed. CMS and OCR, too for that matter, have indicated that 
complaints submitted PRIOR to the enforcement date go no where...that for any 
complaint to be viewed as a valid complaint, it must be submitted AFTER the 
enforcement date = 10/16/03. Before that CMS is not required to take any action.

Rachel Foerster
Chief Executive Officer
Rachel Foerster & Associates, Ltd.
Voice: 847-872-8070
email: [EMAIL PROTECTED]


-----Original Message-----
From: Young, Brian [mailto:[EMAIL PROTECTED] 
Sent: Thursday, June 12, 2003 10:59 AM
To: WEDI SNIP Testing Subworkgroup List
Subject: RE: your post on submitting clean transactions


The "one offs" that we have all ran into will slow us 
all down and I agree that complaints need to be made. 
However, making a complaint at this time has 2 problems
in my view.

CMS, itself a covered entity, does not have all of it
"ducks in a row."  Nor, as was mentioned in a conference
I attended on Monday this week, will complaints filed
at the web site be used until later.  Admittedly I am 
paraphrasing the CMS's rep who said this, but the statement implied to me, they have 
enough on their plate at this 
point and that complaints will just pile up.

So if the watch dog is busy doing other things, how will
making the complaint help?

    BCY

Brian C. Young
Accu-Med Services Inc.
An Omnicare Company
300 TechneCenter
Milford, OH 45150
513.831.1207

-----Original Message-----
From: Thaler [mailto:Thaler]
Sent: Thursday, June 12, 2003 11:56 AM
To: WEDI SNIP Testing Subworkgroup List
Subject: RE: your post on submitting clean transactions


Too bad we have to use the word revolt - but some entities only learn through 
education that is "enforced". There is a complaint form at 

https://www.cms.hhs.gov/hipaa/hipaa2/support/correspondence/complaint/defaul
t.asp?

Patrice 

-----Original Message-----
From: Kepa Zubeldia [mailto:[EMAIL PROTECTED]
Sent: Thursday, June 12, 2003 10:08 AM
To: WEDI SNIP Testing Subworkgroup List
Subject: Re: your post on submitting clean transactions


Jeff,

You ought to complain about this!  The problem is that if nobody complains, it 
will never get fixed.  Providers need to start a "revolt" against these 
frivolous companion guide requirements.  The fragmentation of the standards 
into "custom" versions is probably one of the biggest threats that HIPAA has, 
and one of the many reasons why the implementation is going so slow.

Kepa




On Thursday 12 June 2003 06:49 am, [EMAIL PROTECTED] wrote:
> Kepa,
> 
> As a provider, I'm seeing quite the opposite of what you say about 
> clean transactions, here in the real world.
> 
> Regardless of the fact that federal regulation require a payer to 
> accept a clean X12 claim, they will do what works for them.  Our local 
> Medicare carrier has been pretty good at sticking with the IG, but the 
> local Blues here came out with a 2" thick binder for the companion 
> guide documents. Many of the segments are in absolute contradiction to 
> the IG.  When I called them on this, the response was 
> simple...."follow the companion guide, or else the claims will get 
> bounced on the front end edits.  And since the front end edits are 
> done before the claim enters our processing system, if its 
> noncompliant, it doesn't get into the system."  (Legal speak for "we 
> never got your claim".)
> 
> Never bothered to complain to CMS, as I need to get paid; not worry 
> about the IG implementation.  For most small providers, the 800 lb 
> gorrilla leads the way.
> 
> The software just winds up with a lot more conditional branches that 
> it should have, but the cash flow continues.  We've been sending X12 
> claims to Medicare and Blue Shield now since April, with no problems 
> so far (knock on wood).
> 
> Jeff Pinsky
> PTFILE Systems


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