HIPAA Helpful Hints

HIPAA Transaction implementation assistance from the experts


What are the HIPAA Helpful Hints?

This web site represents a labor of love. After many years working with the X12 transactions, and seeing the HIPAA deadline getting closer every day, a few of us decided that it was time to write down our knowledge of the HIPAA transactions. The HIPAA Helpful Hints is an accumulation of the unofficial knowledge around the implementation guides. Its purpose is to help those who were not intimately involved in writing the guides to understand them. It is not ‘complete’ in the sense that not every decision has been documented, but it still offers insights into the guides and how they were intended to be used. The HIPAA Helpful Hints share our experiences, what works, what does not work, in summary, what is the spirit of the implementation guides.


Who wrote them?

The “we” in this process began with a small group of five people who met together for three days. These five people are just the beginning: we hope to gather a lot more expertise into these documents over time. One of the ongoing problems at X12 is continuity. X12 is a voluntary organization: people come and go as their employers allow. What has happened is that only a few people that have been providing the continuity to these transactions. We are seeking additional contributions from those experts among you that constitute the X12 institutional memory and know why we made certain decisions, so we can reflect them here.

 

The core group that has begun the HIPAA Helpful Hints have been working on these transactions for over ten years now. Our employers process millions of healthcare transactions per day, some in X12 and some in older legacy formats. We are up to our eyebrows in X12 grease. And we have navigated into every X12 sandbar and been caught in numerous data storms. Some of us wrote the first healthcare X12 implementation guides back in 1991, and some wrote the HIPAA guides themselves. We have seen the evolution and migration of these transactions from their youth through their current adolescence. But, in the growth process we forgot to keep a diary. So, today is the day when we look at the HIPAA guides and some times scratch our heads and say "why did we do that?" or "what was the sequence of decisions that we followed to get to that point?"


Answering Your Questions

There is also another motivating factor behind this effort. We find ourselves answering questions about these guides. The same questions repeated multiple times. Some times questions on topics we never expected. Some times questions about the things that are just wrong in the guides. So we want to answer these questions in a manner that can be used for reference by the rest of the industry.

 

As you probably know by now, the HIPAA implementation guides are somewhat obscure in some areas. It is not entirely our fault. The guides need to adhere to certain rules in their presentation, in their content, in the requirements. Some issues are left up to the implementers without guidance on how to actually do things. Other issues are so pedantically defined that makes their current implementation very difficult. We thought we would have a set of HIPAA Identifiers (Provider, Payer) to go along with the guides, and we still don't have those. The lack of identifiers complicates the implementation a little. The HIPAA Helpful Hints tries to fill in and clarify some of the gaps left by their creation process.


The Transition Period

And, most of us are facing a transition period where old systems must coexist with new systems. For some time, at least one year, perhaps more, we are going to live with old pre-HIPAA systems sending data to HIPAA compliant systems. And with new HIPAA compliant systems sending data to old legacy systems. The data available from one party is not what the other party needs in order to process the transaction. We need to be accommodating of these situations, otherwise the transition period will turn into a non productive period. The scary part is that we are already seeing proprietary solutions to this transition period, and if we continue along that path, the transition will soon turn into chaos. We see it coming. And not only the transition. The lack of a good understanding of what needs to be done to implement the HIPAA transactions is already producing unique interpretations that will result in systems that don't interoperate, even though they may be theoretically in compliance with the guides.

 

So, we thought that providing the industry with some additional guidance is the thing to do. We also know that if we take our knowledge through the "official" channels, not only it will take forever, but the resulting "guidance by committee" will be totally washed out. So...

 

A few of us got together to write "The HIPAA Helpful Hints" for the HIPAA transactions. We describe here how things are supposed to work. How we would implement the transactions if we were in your shoes. What is the path of least resistance.


Nothing Official

This is NOT an official document. It is not a consensus document either. It has not been approved by any committee. It has not been approved by our employers either. In fact, while putting these together we found out that, in every single case, in our own systems we were doing something wrong. Even us, the "experts" had interpreted some things different among ourselves. As a result we are having to change every single one of our systems, so we interpret the data the way it was supposed to be. Even though this is some extra work today, it will simplify things for tomorrow. Our employers will be grateful, we hope. And we don't want you to make the same mistakes, so we are offering this guidance to help you along.


Pragmatic and Sometimes Controversial

Does this give you a sense of "underground" effort? We rather think of it as "grassroots" effort, but the result is the same. It is certainly very pragmatic. We have made some decisions that are controversial. We know there will be a good number of X12 "purists" many of which are our dear friends that will not like some of the decisions we have made. In fact, some of those decisions go against the grain of X12 efficiency. We are asking to repeat certain data structures in situations where the guide describes the most efficient way that does not involve repetitions. But we had to make choices between the pure X12 efficiency and what legacy systems can process today. The compromise, in general, is still compliant with the HIPAA implementation guides. As the HIPAA deployment comes to an end, some of these decisions will have to be reversed.


Transitional Guides

We are introducing the concept of a set of "transitional" guides that will work with HIPAA compliant systems as well as non-HIPAA legacy systems. Well, we will all have to be tolerant of the imperfections during the transition time. What is that noise? Why are those people carrying torches and making a pile of sticks? Did somebody say "heresy"? Hey, look, they are surrounding us...


Default Values

We also know that the lack of HIPAA identifiers, and other reasons, are causing some of the data to be temporarily unavailable. There are two choices: either send the transaction on paper, or fill the gap with some sort of "default" value instead. We have chosen to define "default" values where the required data could be missing. And we have chosen, in a totally arbitrary manner, a generic "default" that we believe will work for everybody and for all data elements. At least for all the elements that we found to be candidates to using a "default" value. We know some people will complain about our choice. We can't please everybody all the time. But it is better to have a single "default" value than each trading partner inventing their own values.


The Future

The bottom line is that we offer The HIPAA Helpful Hints as a helping hand, so you don't have to stumble on the rocks we stumbled on. We are not asking for anything. If you want to send us an email with your comments and suggestions for improvement, that is great. If you want to send us criticisms, feel free, but try to make them constructive if possible. Words of encouragement and gratitude are also accepted.


How can you contribute?

We have setup a mailing list at hhh@afehct.org for you to participate. Go to the www.afehct.org site and sign up for the mailing list if you feel so inclined. All the messages will also be logged and available in this web site. It is a simple chronological message log, but will save you from having to store all the discussion yourself. We don't have time to moderate the discussion, and our participation may be limited, but, it is your forum after all. We hope nobody abuses it.

 

As time goes by, we expect these documents to be updated periodically. We will post the date of each update. But this will all be very informal, and we don't have a pre-set schedule. In fact, the first releases may be rather "raw" since there is still a lot of work in progress. Things will get better. Just give us some time and come back for more.

 

The funding for this project comes both from our employers and from us personally. We have taken a good number of days to put this together, knowing that the email and phone messages were piling high. Our employers have pitched in with our scarce time, travel expenses for meetings, phone conferencing, meeting space, food, even candy. It has been a learning experience for ourselves. The entire industry will benefit from it.

 

Enjoy!



The HIPAA Helpful Hints


Updated 7/15/02