When testing 005010X215 Health Care Services Review - Inquiry and Response transactions using an external compliance validation tool, a SNIP Type 4 HIPAA edit was encountered for the response (BHT02=49). The Inquiry Response failed with message H46489: The Previous Review Authorization Number (REF01=BB) should not equal the Trace Number (2000F/TRN02).

Our organization interprets that the edit is valid, in that each value should be unique based on TR3 guidance provided in Front Matter, TR3 Notes, and X12 Purpose information. A clearinghouse partner disagrees—their interpretation is that the TR3 does not contain explicit prohibitive language (i.e., values cannot be the same).

We believe this TR3 detail is rationale for distinct values:

• Front Matter 1.11.4 Matching the Inquiry with the Response (UMO TRN section) states, in part: “UMOs can add a trace number in their own TRN segment in the same loop on the response. The UMO cannot use this trace number to identify the certification to the requester.”
• The value in REF02, with qualifier BB, represents episode-of-care certification identifying information—the unique Previous Review Authorization Number assigned by a UMO.
  • The REF Segment TR3 Note for 2000E states, in part: “This is not the trace number assigned by the requester.”
• The value in TRN02 represents an entity-specific transaction trace identifier—the unique Patient Event (or Service Event) Tracking Number.
  • TR3 Semantic: “TRN02 provides unique identification for the transaction.”

Is it non-compliant to report identical REF02 and TRN02 values in a 005010X215 278 response transaction, or is identical value usage intended to be managed via agreement between trading partners?