Why use a 3rd party, such as Rx Contracts, to de-identify?
Because it is impracticable for the de-identification to happen at the source (MCO/PBM) or the target (Manufacturer). If it cannot happen at either end, it has to happen in the middle.
Can the MCOs/PBMs de-identify?
Not effectively, because they will mask away claim duplication: They will each use their own de-identification methodology, and as such they will each create a different de-identification code for the same prescription number, where such duplication exists. The manufacturer will no longer be able to identify duplicates between their customers, and that would be unacceptable.
Can the Manufacturers de-identify?
Sure, but that might be cumbersome: 1. They would have to become business partners with each MCO/PBM 2. They would have to become PHI custodians 3. They would have to comply with HIPAA regulations about safeguarding the PHI 4. They would have to adjust their software to do this de-identification. A much simpler solution is to hire a third party to de-identify the data before it gets there.
What is the business model?
The manufacturers retain us to become the business associates of the MCOs/PBMs, de-identify for them, and re-identify if/when necessary. The MCOs/PBMs do not have to de-identify at all. The manufacturers do not have to concern themselves with HIPAA obligations in that area.
What HIPAA risk can RxContracts eliminate for me, the manufacturer?
If you receive PHI from your customers as part of the rebate process, you have potential liability to patients if you wrongly use or disclose their PHI, even though HIPAA would not impose liability on you directly.
How can RxContracts eliminate HIPAA risk associated with rebate processing?
De-identified information is not PHI.
Because you do not receive any PHI, you have no risk of misusing patients’ PHI.
Your customers are the Covered Entities.
We will become their Business Associate.
You will direct your customers to send script-level data that may contain PHI to us.
Under this arrangement, HIPAA requires that we enter into a “business associate agreement” with your customers.
Under this agreement, we provide assurance that we will safeguard the original data containing the PHI.
We will provide you copies of the de-identified information.
You will be able to use this de-identified information free of any concern that it may contain PHI and the associated risks.
What is RxContracts’ guarantee?
1. That we will implement and maintain adequate safeguards to prevent any impermissible use or disclosure of PHI received from your customers.
2. That, upon termination or expiration of the business associate agreement, we will return or destroy all PHI received from your customers back to them.
3. That all the data we send you will contain no PHI.
4. That the de-identified information cannot be re-identifiable by anyone except ourselves.
5. That our de-identification algorithm does not use any type of keyed-hash message authentication code methodology.
6. That, in the event that re-identification is required, PHI will only be communicated to your customers, and specifically not to you.
What happens if the HIPAA Privacy Rule changes?
We will let you know immediately, and we will implement any and all such changes as applicable in order to comply with the requirements of the HIPAA Privacy Rule.
Do you perform this service today?
We have been live since February 11, 2003.
How do you de-identify the data?
Our proprietary algorithm ("SER") substitutes every piece of Individually Identifiable Health Information with a unique code (the "SER-code"). All identical such information takes on the value of that one SER-code. No other such information takes on the value of that SER-code. You can use that code to identify duplicates, pay invoices, do counts, etc. just like you do today.
What do SER-Codes look like?
The patient name is typically not on such datasets, but this is what it would look like if it were.
Working with de-identified data: How do we handle a rebate invoice dispute, or an outlier?
You channel these issues through us.
When you communicate with us, you will use the de-identified data (i.e. the SER-codes).
When we communicate with your customer, we will re-identify, and substitute the original Individually Identifiable Health Information.
Other than the re-identification of the SER-codes, your entire communication with your customer will remain intact.
Working with de-identified data: How do we handle a product recall?
We will need verification about the recall from a public source.
Once that verification is obtained, we will pass that communication along to your customers.
When we communicate with your customers, we will replace the SER-codes with the original Individually Identifiable Health Information.
Working with de-identified data: How do we handle Statistical Analysis?
Exactly the same way you do today.
The SER-codes will give you the same distinct counts that you would have gotten from the Individually Identifiable Health Information.
Working with de-identified data: How do we do Quality Assurance?
Exactly the same way you do today.
You will just not be able to identify individual patients.
How much does this service cost?
Please contact us for a quote, stating the number of rebate contracts, how many are paid quarterly versus monthly, and the total annual scripts.
How can we save on cost?
You can ask us to "blot out" the data instead of SER-coding it.
Blotting out is a crude way to de-identify information:
Instead of distinct SER-codes you will see asterisks for alphanumeric data, and zeroes for numbers.
Blotting out is cheaper than running the SER algorithm - and we will be pleased to pass the savings along to you.
Also, blotting out means that you will forego statistical analysis, and that re-identification will become slightly more cumbersome.
To optimize, you might request us to use the "blot-out" mechanism initially.
Then, if you wish to do data analysis on a specific file, you can ask us to re-process the original, only this time through the SER algorithm, and thus get the SER-codes for the analysis.
If you analyze only up to 65% of the files you get, this method is more cost effective.
What if the data supporting an invoice does not have any Individually Identifiable Health Information?
We will review it, certify that it is free of such information, and send it to you. We will not maintain copies.
What happens to the customers' original data containing PHI?
We will safeguard it for the duration of the business associate contract for a nominal monthly fee.
Upon termination or expiration of the business associate agreement, we will return it to the customer or destroy it and give you and your customer a destruction certificate.
If we retain Rx Contracts for HIPAA de-identification, will we have to retain same for Rebate Processing as well?
No. But you will probably want to!
Why should we spend any money for when we are currently not doing so?
Even though Data Processing is not your line of business, you spend indirect money now to process dissimilar data from your customers.
Let us streamline the processing, get all your data in a consistent look, and give you the time to focus on your main line of business!
How can we process an invoice in just 10 minutes?
For the normal cases:
You receive an e-mail.
You review the information in several cuts.
You click the pushbutton.
The invoice gets created right into your payables system.
Your script-level data is still all available for scrubbing and other uses.
For the problematic cases, you get contacted long before any invoice gets created.
How can we reduce our overall rebate costs?
Negotiate with your customers payment terms that work better for them!
No matter what payment terms you agree with your customer, RxContracts, Inc. will be there for you.
For example: Should your customers wish to get paid monthly, agree on a lower rebate and pay them monthly.
They will be able to afford the lower rebate, because they will not have to incur short-term borrowing costs to convert the quarterly rebates into monthly cashflow.
There is no burden in monthly rebates, either: Your customers only need send us monthly their electronic scripts, plans and formularies; no need for summaries, cover letters, or other custom reports.
Why should we choose RxContractsTM Rebate Invoice Processing Service instead of the competition?
Unlike our competition, our fees are both miniscule and flat.
Do you work for companies that receive rebates as well?
Never FOR them. But we have technological exchanges with them all the time.
How much does the service cost?
That depends on the size and needs of your company.
If you tell us the scope of the rebates that you are paying, will be glad to let you know.
Also, there are discounts available if you use our HIPAA service as well, because your data will already be in our place.
If we retain you for this service, will we also have to retain you for HIPAA de-identification?
No.
What are the Rebate Effectiveness Reports?
Every month you will get a stand-alone report generator enabling you to create thousands of report "cuts", and charts.
The charts show you Utilization, Sales, and Rebate amounts by business partner, by product, by product line, by quarter or last 4 quarters.
You will be able to tell how effective the rebating is.
There is no additional software that you need to install; everything will already be compatible with your PC or laptop.
Additionally, you will be able to export the underlying data to the in-house reporting system of your choice.
How secure is our information?
We have strict security procedures in place.
Internally, your information can be accessed only by those with absolute need-to-know.
We perform background checks on all job applicants.
When we send you your data over the internet, we encrypt it using 128-bit encryption.
What is the RxMiniTM formatted data file?
The spreadsheet that we send you contains an Approval pushbutton.
You click that in order to approve the rebate - and that clicking action creates the RxMiniTM formatted data file, which is a very small text file on your PC.
This file can be easily imported into any Financials system using the RxAdapterTM data conversion program.
What is the RxAdapterTM data conversion program?
The RxAdapterTM data conversion program is a program that your company can write (or we can help write for you), as a one-time effort.
This program automatically imports the RxMiniTM formatted data file directly into your Financials System with as few keystrokes as possible.
Writing the RxAdapterTM data conversion program completes the automation and saves you time, the cost of data entry, and the related error potential.
A customer of ours (who uses the SAP R/3 system for their Financials) approves payment and creates each credit memo with literally 7 keystrokes.
Manufacturers can use the RxAdapterTM data conversion program to create credit memos in their A/P.
Payees can use it to create their invoices in their A/R.
What happens if I click the Approval pushbutton by accident?
The RxMiniTM formatted data file will get created, but nothing will really happen until you invoke the RxAdapterTM data conversion program.
The name of the RxMiniTM formatted data file is always c:\RxMini.txt, so you do not have to worry about remembering what you saved it as, or finding too many extra files on your PC.
Next time you click an Approval button, from this or other Rebate Analysis workbook, the file will get overwritten with a new one.
How is your scrubbing different from your competition's?
We do not charge you a fee for scrubbing the data. We charge you only a percent of any inappropriate claim amounts that we find.
If your sales volume is not in the top 5 in the country, our pricing structure is more beneficial to you than the fixed-fee pricing structure of our competition.
What do you mean by archiving?
For Rebate processing (unlike for HIPAA de-identifying) we archive your information free for the first 50 months - which covers the 4-year requirement.
At around the 48th month we send you an e-mail reminding you that the grace period is about to expire.
At that or any other time you can ask us to destroy any one or more of the archives, and/or send them to whomever you wish.
After the first 50 months archiving can continue for a nominal fee.
Whom are you outsourcing?
NOBODY. We are only filling a gap: From the Payees' utilization data to the Manufacturers' invoice.
This gap represents work that is now processed manually, usually with ad-hoc spreadsheets, by people who have much better things to do with their time.
Do you outsource our Contract Administrators?
No, in fact, quite the opposite.
We depend on these Contract Administrators to tell us which contracts are active, which are getting extended, amended, etc.
In addition, we count on these people to tell us if their customers have met Formulary requirements, and advise us of any special circumstances and priorities.
Lastly, as we remove from these people the chore of processing dissimilar data, these Contract Administrators find themselves spending their time administering their companies' contracts, and being happier and more effective overall.
Do you outsource our IT Departments?
Not at all.
These people are used to writing a special adapter programs, usually one for each payee, in order to send each data submission into their A/P.
By using the RxMiniTM formatted data file we are making their life easier, as the format is uniform regardless of source.
Since the format is uniform, one single adapter program suffices!
We offer to write the RxAdapterTM data conversion program for our customers only as a last resort, if the IT department is too busy to help out.
Do you process Chargebacks?
No.
Do you process Medicaid Rebates?
No.
Is your solution a permanent one?
Our approach is only the beginning of e-commerce.
Full e-commerce will be when you only need a browser - and not even a spreadsheet.
The timeline to full e-commerce is directly related to digital signatures.
As soon as digital signatures become a more mainstream technology, you will be able to do the entire contracting and rebates adjudication over the internet.
Anything else?
Please ask us!
