Operationally, what is the meaning of "data content" in direct data entry processes?
The final rule defines data content to mean "all the data elements and code sets inherent to a transaction, and not related to the format of the transaction. Data elements that are related to the format are not data content". The preamble also goes on to explain that in the case where one is conducting a transaction via "direct data entry" process using a computer browser screen that one need not comply with data format but must comply with data content.
In a recent WEDI SNIP meeting a question came up and was discussed at some length as to the meaning of "data content". Most agreed that some data elements found within HIPAA X12 transactions are obviously related to format. For example, the ISA/IEA, ST/SE, and HL segments exist solely for the transmission of X12 transactions and have nothing to do with the substance of the transaction. The data carried in these segments would be classified as data format. However, some data elements are not so easy to classify. For example, the BHT04 of the 837 claim transaction contains the date that the submitter created the file.
If this claim transaction was being conducted as a direct data entry process would the submitter need to fill in the day's date or would it be sufficient to have the transaction date/time stamped when the submitter hit the "SEND" key?
Or another example; when a provider logs onto the direct data entry system hosted by a payer, the payer's system automatically knows all of the information needed to complete the Source and Receiver portion of the transaction. Must the provider key in their name, address, phone number etc. each time they want to conduct an eligibility inquiry? Or can the payer's system overlay that data content automatically? In both cases the data content is available and a compliant transaction can be created - the only difference is that the person completing the transaction does not need to see ALL of the fields that make up the compliant transaction since some data can be derived.
Data content requirements, other than X12N format requirements, must be included on direct data entry transactions at the time the transaction is being sent. X12N format requirements include all the enveloping and structure segments, such as the ISA/IEA, ST/SE, and HL segments. In cases where data content, such as name and address information is available from other sources, such as the health plan's database or, in the case of date/time stamping, generated by the system's software, the person entering the data does not necessarily have to "see" the data, but the data content requirement must be met before the transaction reaches the health plan's system.