What is the background of this payment standard for healthcare payments?
On January 10, 2012, the US Department of Health and Human Services (HHS) issued Administrative Simplification: Adoption of Standards for Healthcare Electronic Funds Transfer (EFT). This directive standard became final on July 10, 2012.
What does the payments standard do?
The standard defined "healthcare EFT" as a transaction under HIPAA for the first time.
As a part of the rule, does the standard identify an agreed-upon payment method?
Yes, the standard identified NACHA CCD+ Standard Entry Class (SEC) as the agreed-upon payment method.
What is the advantage to receiving payments via EFT in conjunction with this standard?
The EFT standard calls for several changes to be considered a healthcare EFT. More specifically, by using the CCD+ SEC, by default there must be one line of additional remittance information included with the payment, or "addenda." The addenda information must contain the ANSI ASC X12 TRN data segment found in the TRN 02 position, which conveys the TRN used by the healthcare provider to match the payment to remittance data (match the dollars to an identifier on the EOB/ERA). Additionally, the standard mandates the receiving bank (e.g., RDFI) must make available this reassociation data no later than the opening of business on the second banking day after the transaction settlement date.
Are HIPAA-covered entities required to use the NACHA ACH network to transmit and receive healthcare claim payments by EFT?
No. As of January 1, 2014, health plans (e.g., insurance companies) and medical providers (e.g., doctors, hospitals, clinics) are not prohibited from using other networks such as wire, card payment networks, etc. However, if a provider requests a health plan conduct EFT using the ACH Network, the health plan is required to do so. Regardless of the network used, every effort should be made by the health plan to ensure that reassociation between the payment and remittance advice can be automated by providers.
When was this standard effective?
Changes to healthcare-specific EFTs were effective by September 20, 2013.
With respect to being considered a healthcare EFT payment, what else does the standard mandate?
The details within the NACHA Operating Rules and CCD+ standard are being refined to align with Healthcare Operating Rules. To comply with the new rules and be considered a healthcare claim payment, the transaction and data must adhere to the following:
- The ACH payment transaction must be a CCD+ entry (healthcare EFT must include one addenda record).
- The company entry description must have "HCCLAIMPMT."
- Banks' ACH processing platforms must support a terminating symbol; prior, it was "\"; for healthcare EFT a symbol that was also accepted was "~".
- The rule also mandates that banks must offer at least one secure method for delivering this data.
- The "7" Record (CCD Addenda) must contain the ANSI ASC X12 TRN data segment found in the TRN 02 position, which conveys the TRN used by the healthcare provider to match the payment to remittance data (match the dollars to an identifier on the EOB/ERA.
- The receiving bank (e.g., RDFI) must make available this reassociation data no later than the opening of business on the second banking day after the transaction settlement date.
Insurance/health plan entities
My company is an insurer and currently pays medical providers via ACH and checks. What do I need to do to comply with the standard?
If your medical ACH receivers and originators are doctors, medical practitioners, hospitals, health systems, etc., here is what you need to know:
- All health plans are required to be in compliance of the formatting standards for EFT and ERA and must be prepared to pay via ACH, if requested by provider.
- NACHA CCD+ Addenda is to be used as the standard to transmit EFT payments.
- Health plans are required to include the TRN for payments and associated data to link the payment to the electronic advice or ERA.
- All health plan EFT payments must contain a unique identifier indicating they are healthcare (use of "HCCLAIMPMT" in company entry description field).
- If payment to providers is made by check, no changes are required.
- If payment is made by EFT, but advice is sent by paper EOB, no changes are required.
My company is an insurer and currently conforms to this standard (prior to the September 20, 2013, mandate). What other action do I need to take?
The rule mandates if a provider requests a health plan conduct EFT using the ACH Network, the health plan is required to do so. We have found several plans in the marketplace that have updated and complied with this standard. BB&T is able to process these outgoing disbursements via the ACH Network. As the standard is firmly in place by September 20, 2013, there will likely be more and more adoption and requests by medical providers to receive their healthcare claim payments via EFT. As such, we advise you to review your processes and procedures so you have a way to indicate to the medical providers how to communicate to you that they wish to begin receiving payments via EFT.
Where can I get more information on the new healthcare EFT standard?
For additional detail, go to healthcare.nacha.org/nacharuleshealthcarehttps://healthcare.nacha.org/nacharuleshealthcare (opens in a new tab).
My company is a healthcare provider/receiver of payments. What do I need to do to comply with the standard?
- You may ask your financial institutions to provide any healthcare payment related information, including TRN, to you upon request in a secure manner. BB&T is prepared to handle these requests from you.
- As a provider, you may request that a health plan pay you electronically instead of by paper. This is your decision as you evaluate ways to post your claims more efficiently. The health plan should make every effort to not only provide the payment electronically but also make every effort to ensure ease of reassociation to the remittance advice.
- No changes are required if you continue to receive paper payment and/or paper remittance advice.
- If you do not receive electronic payments today through BB&T, but would like to explore that as a payment option, you can contact your BB&T representative for assistance.
What is BB&T doing as a receiver of incoming insurance company payments on my behalf to help comply with the healthcare EFT standard and the associated rules?
As a receiving depository financial institution (RDFI), BB&T is prepared to comply with all aspects of the standard and associated rules. BB&T will provide payment-related information upon request by our clients who are receivers (medical providers).
When will I be able to access the transaction reassociation number?
Per the rules, receiving banks are required to make available the TRN data by the opening of business on the second banking day following the settlement date of the entry.
What are the charges for my company to receive the EFT and TRN?
At this time, BB&T will not charge fees for this additional data reporting service. However, there may be fees associated with accepting incoming ACH transactions. Please discuss this with your Payments Solutions Treasury consultant.
My company is a healthcare provider receiver of payments. How do I request to begin receiving my healthcare claim payments electronically?
You should contact your various insurance company partners who process and pay claims to you to determine the best and easiest way to communicate that you would like to begin to receive your payments electronically using the ACH network. Regardless of whom the insurance company is, BB&T will present the payment and associated information in compliance with the EFT Healthcare Payments standard.
Technical aspects of the healthcare EFT standard and rules
How will originators of payments indicate these ACH payments are healthcare EFT payments under HIPAA?
In conjunction with the rule, field seven of the Company Batch Header record (aka the "five record") is known as the Company Entry Description field and will indicate this is a healthcare claim payment. This field is a mandatory field (it must have data), it can be alpha-numeric and a maximum of 10 characters. The purpose of this field is to provide a description of the transaction to the receiving entity. The new healthcare EFT standard requires the description shall be "HCCLAIMPMT."
The ACH standard that has been identified is the NACHA CDD+ Standard Entry Class (SEC) as the EFT standard. Can you provide more details about this?
The rules state the CCD entry that is a healthcare EFT must include one addenda record. Also, the addenda indicator must be populated with a "1." As such, when populated with a "1," there must be one addenda record. CCD Entries that are healthcare EFT transactions must contain the ANSI ASC X12 TRN data segment, which conveys the TRN used by the healthcare provider to match the payment to remittance data. (ANSI is the American National Standards Institute; ASC is the Accredited Standards Committee.)
Can you explain and provide an example of the addenda record contents?
- Data Segment Identifier (always "TRN"; in examples below it is indicated as "TRN")
- TRN01 - Trace Code Type (minimum of one character, maximum of two characters; required field; in examples below it is indicated as "1")
- TRN02 – Reference Identification (reassociation number; minimum of one character, maximum of 50 characters; required field; in examples below it is indicated as "12345")
- TRN03 – Originating Company Identifier (payer identifier; must be exactly 10 characters min/max; required field; in examples below it is indicated as "1512345678")
- TRN04 – Reference Identification (minimum of one character, maximum of 50 characters; situational field; in examples below it is indicated as "99999")
- Example: TRN*1*12345*1512345678*99999\
- Example: TRN*1*12345*1512345678*99999~
In the previous example, there are two different symbols at the end of the addenda record. What does this mean?
Banks' ACH processing platforms must support a terminating symbol. In the past, the universally accepted symbol to denote the end of the record was a backslash (\). However, with the new healthcare EFT standard, the rules call for banks also supporting the tilde (~) symbol. The BB&T ACH processing platforms were updated to support both the prior commonly used standard of the backslash as a terminating symbol as well as the tilde symbol.
Ready to get started?
Have a Treasury Management representative contact you.