I know that some separate guidelines have been published by HCFA defining what constitutes acceptable encryption for them. Our clients are clamoring for more clarification, and more examples of what will be required. One major HIS vendor tells me that because the company has a single product line, the implementation calendar does not represent a problem. For many others, however, the issues are less clear. The underlying belief is that two years isn't a lot of time to do something as big as that.
Coordination is the name of the game.
Other vendors, however, have suggested that the rules be amended to call for compliance on all parts of the regulations on one specific date. I realize that this may be beyond what this committee can recommend, but I ask you to keep this in mind, particularly if implementation deadline delays are ever discussed. The continuing delays in publication of the final regulations are frustrating to them. While we appreciate the volume of work to be done, and understand that a rough timetable has been proposed, we encourage you to support rapid publication of the remaining rules. They don't even define business partner.