PROVIDER PAYMENT RIGHTS AND THE HEALTHCARE EFT STANDARD & OPERATING RULES Priscilla Holland, AAP Senior Director, Healthcare Payments NACHA – The Electronic Payments Association WA AK HFMA Alaska Conference November 19, 2013 © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Who is NACHA? • Standards rulemaking body that administers the ACH Network • NACHA Operating Rules: • Establish the legal foundation for the ACH Network • Provide a common set of rules and formats • Create certainty and interoperability • Prescribe roles and responsibilities © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 2 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD What is the ACH Network? • The ACH Network: • Facilitates global commerce by serving as a safe, efficient, ubiquitous and high-quality electronic payment system; it is best known for Direct Deposit and Direct Payment • Is accessible via more than 13,000 U.S. financial institutions • More than 21 billion ACH payments in 2012, moving $36.9 trillion in value © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 3 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD How does this impact healthcare payments? • The Healthcare EFT Standard is the CCD+Addenda, an ACH Network format. • NACHA is the standards body for the healthcare EFT standard. © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 4 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Changes to the NACHA Operating Rules to Align with Healthcare DETAILS WITHIN THE NACHA OPERATING RULES AND CCD+ STANDARD ARE BEING REFINED TO ALIGN WITH HEALTHCARE OPERATING RULES1 Overview of NACHA Rule Changes Detail Standard Identification of Health Care EFTs The rule requires health plans to clearly identify CCD Entries that are Health Care EFT Transactions through the use of the specific identifier “HCCLAIMPMT” Additional Formatting Requirements for Health Care EFTs For a CCD Entry that contains the healthcare indicator, as described above, the health plan must include an addenda record that contains the ASC X12 Version 5010 835 TRN (Reassociation Trace Number) data segment; and to identify itself in the transaction by its name as it would be known by the provider Delivery of Payment Related Information (Reassociation Number) The rule requires an RDFI to provide or make available, either automatically or upon request, all information contained within the Payment Related Information field of the Addenda Record, no later than the opening of business on the second Banking Day following the Settlement Date. Further, this Rule would require the RDFI to offer or make available to the healthcare provider an option to receive or access the Payment Related Information via a secure, electronic means Addition of New EDI Data Segment Terminator The rule provides for the use of a second data segment terminator, the tilde (“~”), to any data segments carried in the Addenda Record of the CCD Entry Health Care Terminology within the NACHA Operating Rules The rule includes healthcare-related definitions 1Changes were effective September 20, 2013 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Healthcare EFT Transaction Volumes Sep-13* Number of Forward CCD Credits Total $ Value of CCD Credits Number of Forward CCD Debits Total $ Value of CCD Debits Total # of addenda records with forward debits and credits Number of Returns of CCD Credits and Debits Average $ value of credits Avg # of credit trans per business day % of transactions with addenda records * Only 7 processing days in Sept 2013. Changes implemented 9/20/13 Oct-13 Y-T-D Totals 1,319,207 5,628,162 6,947,369 $ 7,467,200,857.99 $25,090,277,618.94 $32,557,478,476.93 1,555 4,289 5,844 $1,714,608.54 $562,345,466.55 $564,060,075.09 1,293,744 5,630,232 6,923,976 534 1,251 1,785 $5,660.37 $4,457.99 188,458 255,826 97.95% 99.96% © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 6 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD What is the Healthcare EFT Standard? © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 7 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD CCD+ Addenda: The Healthcare EFT Standard • Patient Protection and Affordable Care Act (ACA) mandated the identification of a HIPAA standard for EFT transactions and the development of healthcare operating rules to support the HIPAA standard transaction • Allows you to directly receive health plan claims reimbursements in your bank account, like Direct Deposit • Only payment option required to offer providers the ability to automatically reassociate remittance information with the payment © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 8 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Healthcare EFT & ERA Standards + Operating Rules EFT & ERA Standards EFT & ERA Operating Rules ACH CCD+ & X12 v5010 835 CAQH CORE EFT & ERA Operating Rules • EFT: NACHA CCD+Addenda (must contain the TRN Reassociation Trace Number data segment as defined by X12 835 TR3 version 5010) • ERA: X12 v5010 835 • Health Care Claim Payment/Advice (835) Infrastructure Rule • Uniform Use of CARCs and RARCs (835) Rule • EFT & ERA Reassociation (CCD+/835) Rule • EFT Enrollment Data Rule • ERA Enrollment Data Rule Admin Simplification Together, EFT & ERA Standards and Operating Rules will deliver efficiency and consistency across the healthcare industry © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 9 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Healthcare Payment Chain Provider 1. Patient Encounter with Provider Health Plan 1 3 2. Provider submits Claim (837) to Health Plan 3. Health Plan Adjudicates Claim 2 4. *Health Plan sends Electronic Remittance Advice (ERA) (835) to Provider. The ERA contains TRN Reassociation Trace Number 8 4 5 7 5. *Health Plan sends CCD+ to ODFI for Claim Reimbursement, including a matching TRN Reassociation Trace Number 6. ODFI Sends ACH CCD+ Addenda through ACH Network to RDFI 6 7. RDFI receives CCD+ for Provider, deposits credit to Provider account, and delivers the TRN Reassociation Trace Number to Provider RDFI ODFI ACH (Receiving Bank or Operator (Originating Bank or 8. Provider Reconciles the payment and ERA Credit Union) Credit Union) by matching the TRN segment from both *The CCD+addenda and ERA are generally not sent on the same transactions (#4 and #5) day. CAQH CORE operating rules establish max timeframe for distribution. © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 10 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Healthcare EFT Standard- Final Rule Summary • Identifies the Healthcare EFT Standard as a HIPAA Standard • 45 CFR § 162.1602 • Health plans are required to deliver HIPAA Standards if requested by Provider • 45 CFR § 162. 925 • Does not require providers to receive health plan payments via the Healthcare EFT Standard (can still request a check or other EFT options) • However, all Medicare payments will come via the EFT Standard • Neither prohibits nor adopts any standards for health care EFTs transmitted outside the ACH Network © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 11 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Healthcare Standard Final Rule: Standard for Data Content of Addenda Record • CCD+ Addenda enables automatic reassociation of health plan payment with remittance information • Your financial institution can provide you with the information to match the payment with the remittance © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 12 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD What do I need to do to comply with legislation and operating rules for the Healthcare EFT Standard? © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 13 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD High-Level Provider Requirements • Enroll with individual health plans to receive EFT* – Prioritize health plans, 80% of claims reimbursements may come from 20% of plans • Request reassociation trace number from your bank or credit union *Enrollment databases are being developed by organizations to simplify enrollment process © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 14 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD CAQH CORE 370 EFT & ERA Reassociation Healthcare Operating Rule CORE-required Minimum CCD+ Reassociation Data Elements CCD+ Record Field # Field Name Batch Header Record Detail Record 9 Effective Entry Date 6 Amount Addenda Record 3 Payment Related Information • CAQH CORE 370 EFT & ERA Reassociation Healthcare Operating Rule requires that the Provider proactively contact its bank or credit union to receive the Core-required Minimum CCD+ Reassociation Data Elements © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 15 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Terminology When Talking to Your Financial Institution • CORE EFT & ERA Operating Rules: Request the CORE-required Minimum CCD+ Reassociation Data Elements • If your financial institution does not recognize that, try: • ACH Payment-Related Information • ACH Addenda Record Information • Payment-Related Addenda Information • NACHA Operating Rules, Subsection 3.1.5.3 require a financial institution to provide the Payment Related Information to the Receiver if it is requested © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 16 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD When do I need to be ready to accept the Healthcare EFT Standard? Compliance in Effect as of January 1, 2013 Implement by January 1, 2014 Implement by January 1, 2016 • • Eligibility for health plan Claims status transactions • • Electronic funds transfer (EFT) transactions Health care payment and remittance advice (ERA) transactions • • • • • Health claims or equivalent encounter information Enrollment and disenrollment in a health plan Health plan premium payments Referral certification and authorization Health claims attachments Required for all HIPAA Covered Entities © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 17 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD What are others required to do? © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 18 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Healthcare EFT Standard & Operating Rules • Health Plans are required to: • Certify to HHS that they are compliant with healthcare EFT standard and healthcare EFT & ERA Operating Rules by 1/1/14* • Offer payment via Healthcare EFT Standard (CCD+) (required if requested by provider) • Offer electronic EFT enrollment • Originate healthcare EFT and ERA within 3 business days of each other *Certification date is expected to change, but not the implementation date of the healthcare EFT standard and EFT & ERA Operating Rules. © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 19 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Significant Fines for Non-compliance • ACA Section 1104 – Administrative Simplification requires health plans to certify compliance with the healthcare EFT standard and healthcare operating rules by January 1, 2014 • Health plans can be fined • $1 per covered life per day • Not to exceed an amount equal to $20 per covered life per day • Or an amount equal to $40 per covered life under the plan if such plan has knowingly provided inaccurate or incomplete certification information © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 20 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Barriers to EFT Adoption • White paper issues by NACHA and CAQH June 2011, Adoption of EFT and ERA by Health Plans and Providers identified barriers to Provider acceptance of ACH/EFT & ERA for healthcare claims reimbursement. • Provider enrollment with health plans is currently inefficient and timeconsuming due to non-standard processes (EFT Enrollment Data Rule) • Providers often have difficulty matching an EFT with its associated ERA (missing or incorrect trace number) (EFT & ERA Reassociation Rule) • Lack of understanding of electronic transactions, processes and workflows • Providers perceive that the costs and complexities associated with implementing electronic workflows for EFT and ERA outweigh the benefits • Some providers also perceive a lack of control over retroactive adjustments and denials by health plans (including debiting of their accounts). © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 21 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD NACHA Operating Rules Requirements for Financial Institutions • Financial institutions are required to: • Deliver the Payment Related Information (TRN Reassocaiton Trace Number) to the Receiver/Provider if it is requested. – Subsection 3.1.5.3 • Have a secure electronic delivery option available for the provider – Many FIs have multiple delivery options and will work with the provider to determine what delivery method is best for the provider – Providers are not required to receive the TRN Reassociation Trace Number via secure electronic option, but the financial institution must make a secure electronic option available © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 22 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD CAQH CORE in collaboration with NACHA • Were identified as authoring entities for the EFT & ERA Operating Rules • CAQH is a nonprofit alliance of health plans and trade associations collaborating on initiatives that simplify healthcare administration • CAQH Committee on Operating Rules for Information Exchange (CORE) developed voluntary operating rules starting in 2005 that were the foundation for the Eligibility and Claims Status Operating Rules © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 23 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Mandated EFT & ERA Operating Rules: January 1, 2014 Requirements Scope Data Content Rule Uniform Use of CARCs and RARCs (835) Rule • Identifies a minimum set of four CAQH CORE-defined Business Scenarios with a maximum set of CAQH CORE-required code combinations that can be applied to convey details of the claim denial or payment to the provider • • • Identifies a maximum set of standard data elements for EFT enrollment Outlines a flow and format for paper and electronic collection of the data elements Requires health plan to offer electronic EFT enrollment • Similar to EFT Enrollment Data Rule • Addresses provider receipt of the CAQH CORE-required Minimum ACH CCD+ Data Elements required for re-association Addresses elapsed time between the sending of the v5010 835 and the CCD+ transactions Requirements for resolving late/missing EFT and ERA transactions Recognition of the role of NACHA Operating Rules for financial institutions Claim Adjustment Reason Code (CARC) Remittance Advice Remark Code (RARC) Rule 360 EFT Enrollment Data Rule Rule 380 ERA Enrollment Data Rule Rule 382 Infrastructure High-Level Requirements EFT & ERA Reassociation (CCD+/835) Rule • Rule 370 • • • Health Care Claim Payment/Advice (835) Infrastructure Rule Rule 350 • • • Specifies use of the CAQH CORE Master Companion Guide Template for the flow and format of such guides Requires entities to support the Phase II CAQH CORE Connectivity Rule. Includes batch Acknowledgement requirements* Defines a dual-delivery (paper/electronic) to facilitate provider transition to electronic remits * CMS-0028-IFC excludes requirements pertaining to acknowledgements. © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 24 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD What are the benefits of using the Healthcare EFT Standard? © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 25 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Benefits of Choosing the Healthcare EFT Standard • Easy, Automatic Payments – Receiving healthcare EFTs via ACH is as quick as receiving Direct Deposit. • Improved Cash Flow – Healthcare EFTs via ACH ensure funds are available up to 7 days faster than with paper checks. • Safe and Secure – Checks continue to be the dominant payment form targeted by fraudsters. Replacing all checks with healthcare EFTs via ACH is the single best way to combat fraud. © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 26 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Benefits of Choosing the Healthcare EFT Standard • Automatic Reassociation – Only healthcare EFTs via ACH offer providers the ability to automatically reassociate remittance information. • HIPAA EFT Transaction– As a HIPAA transaction, under 45 CFR 162.925, providers can request delivery of the healthcare EFT standard and health plans must comply. • Smart, Cost-Effective Choice – The cost of claims via ACH is, on average, only $0.34 versus $10.73 or more for other EFT payment types. © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 27 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Providers Rights under the ACA • With the exception of Medicare, the provider has the right to determine how they will be paid for healthcare claims reimbursements • Medicare claims reimbursements must be made via healthcare EFT standard effective January 1, 2014 • Providers have the right to receive claims reimbursements via paper check, healthcare EFT standard or other EFT payment options • Effective January 1, 2014 a health plan must deliver claims reimbursement payments via the healthcare EFT standard, if it is requested by the provider © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 28 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Comparison of Electronic Payment Options “make an educated choice” Healthcare EFT Standard (via ACH) Virtual Card Wire Transfer Funds Availability Next Day 2-3 Business days (via ACH) Same Day (funds irrevocable) Average Cost $0.34 (any payment value) Percentage of total payment (avg. 3%) plus a transaction fee $10.73 (any payment value) Enrollment/Acceptance Must have a bank account One time with each health plan Must have a bank account One time with each health plan Risk Very low risk with ACH credit payment Must have a bank account and agreement with a merchant card processing provider, and point of sale processing system/terminal Higher risk with virtual cards Manual processing for each payment None Each payment must be manually entered into the POS terminal by office staff None Reassociation with Electronic Remittance Information Standardized inclusion of TRN Reassociation Data Segment in payment Not included with payment Manual access to each EOB through web portal No requirement to include TRN Reassociation Data Segment with payment Very low risk with immediate payment © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 29 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Using Healthcare EFT Standard (CCD+) Delivers Significant Cost Savings to Providers Example of Acceptance of Different EFT Payment Types for $2,500 claim payment EFT Payment Type Average Quoted Price ACH CCD+ Must include TRN Reassociation Data Segment *ACH Deposit plus Addenda to $ Business Account Virtual Purchasing Card **Per transaction fee Interchange fee 0.34 No TRN Reassociation Data Segment $ 0.10 1.90% Wire Transfer May include the TRN Reassociation Data Segment *Received wire transfer $10.73 • Provider acceptance of ACH CCD+ addenda deposit for any value - $.34 • Payer claim payment of $2,500 made via a Virtual Purchasing card (at Commercial Data Rate 3 interchange) would generate a fee of: • • • $47.50 (interchange – 1.90%) $00.10 (transaction fee) $47.60 Total fee to accept card payment • Provider receipt of a wire transfer for any value - $10.73 *The Blue Book of Bank Prices 2012-13 published by Phoenix-Hecht - https://www.phoenixhecht.com/treasuryresources/PDF/BBExecSumm.pdf ** Card fees published by MasterCard- http://www.mastercard.com/us/merchant/pdf/MasterCard_Interchange_Rates_and_Criteria.pdf © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 30 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Facts Behind the Virtual Card Process • Health plans fax, email or mail the payment information to the Provider • Provider will manually process the claims payment through POS terminal Cost Considerations • Virtual card shifts the costs of payment processing from the health plan to the provider • Providers pay interchange fee and per transaction charge © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 31 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Advantages to Virtual Cards • Providers do not have to enroll with each individual health plan to receive virtual card payments • Easy way to receive claims reimbursement payments from health plans not frequently used • Hospital in Steamboat Springs, CO indicated as a resort town they have patients from all over the world and many health plans that they will receive payment from only a few times a year. The virtual card helps to facilitate the receipt of these payments • If virtual card number is lost or stolen it can be replaced by the health plan (standard card program rules). © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Disadvantages of Virtual Cards • Expensive for providers to accept virtual card payments • Providers pay interchange fee and per transaction charge • Shift the costs of payment processing from the health plan to the provider • Most vendors will rebate a percentage of the interchange fee and/or transaction fees paid by the provider back to the health plan • Providers must manually process the payment by keying the virtual card number into the office POS terminal • If amount of the payment is keyed incorrectly the virtual card is void and must be replaced by the health plan • Cannot receive a HIPAA compliant ERA (X12 835) with a virtual card transaction • Funds are deposited to providers merchant account in 2-3 business days after processing (via ACH) © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Things to consider • • Interchange fee paid by Providers is based on Provider agreement with Merchant Bank Are your receivables clerks already accepting virtual card payments from health plans • Major hospital group “discovered” their receivables clerks were accepting virtual card payments from health plans and the hospital paid over $2,500,000 in interchange fees before the treasury department identified the reason their merchant card fees has increases significantly and stopped the practice • If you have a lockbox, is the lockbox accepting virtual card transactions in place of checks • Some health plans are not asking, but mailing the virtual card information to the providers lockbox instead of a check • Providers are under no obligation to accept virtual card payments for corporate claims reimbursement because the practice accepts card transactions for patients © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 34 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD How do I start using the Healthcare EFT Standard? © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 35 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD 4 Steps to Receiving Plan Payments via the Healthcare EFT Standard 1. Contact health plan and choose the healthcare EFT standard. 2. Provide payment information to health plan. 3. Receive payments directly in your bank account. 4. Contact your bank to receive the Reassociation Trace Number directly. © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 36 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Partner with Financial Institutions to Expand Opportunities ACH and Treasury Management Services Increase electronic patient payments • Become an ACH Originator – Collection of outstanding Patient obligations Improve back office administrative processes • Reassociate remittance information with payment Reduce payment risk • Prevent unauthorized debits to account – Debit Filter or Debit Block – ACH Positive Pay – Account masking (UPIC) © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 37 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD What Can Financial Institutions Do for Providers? • Some financial institutions offer solutions to process claim payments with image to EDI technology for claims payments PLUS ERA retrieval and reassociation services. Bank Receivables Service © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 38 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD How can I learn more? © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 39 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD NACHA Informational Resources Resource Details Healthcare Payments Resources Website https://healthcare.nacha.org/ Health ePayments News Quarterly newsletter Sign up at https://healthcare.nacha.org/ Healthcare EFT Standard Implementation Guide • • • • What is the EFT standard? How does it work? How do I populate the specific fields? What are NACHA Operating Rules and how do they impact the standard? https://www.nacha.org/eStore ACH Primer for Healthcare • • • • • Introduces ACH payments Defines ACH Network, participants and transaction flow Outlines benefits of moving to EFT Describes changes to the NACHA Operating Rules to support healthcare EFT transactions Compares EFT payment options https://healthcare.nacha.org/ACHprimer © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 40 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Additional Resources • AMA EFT Toolkit - www.ama-assn.org/go/eft • AMA Administrative Simplification LinkedIn Group • CAQH CORE EFT & ERA Operating Rules http://www.caqh.org/CORE_phase3.php • CAQH EFT Enrollment Database http://www.caqh.org/eft_enrollment.php © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 41 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Additional Resources • WEDI (Workgroup on EDI) • NACHA Operating Rules Healthcare Updates and their Impact to Providers and Health Plans – Provides background and detailed information on the NACHA Operating Rules updates and their impact to health plans and healthcare providers • Implementing a Healthcare Payment EFT Process to Accompany a Healthcare Claim Payment Remittance Advice – – Provides background and detailed information for health plans and healthcare providers on what is needed to implement EFT Includes checklists for both health plans and healthcare providers • EFT and ERA Enrollment Process – • Provides background on the requirements of CAQH CORE Rules 380 and 382, along with information for health plans, healthcare providers, and vendors to implement these requirements. http://www.wedi.org/knowledge-center/documents/white-papers © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only. 42 SIMPLIFYING PAYMENTS WITH THE HEALTHCARE EFT STANDARD Questions Priscilla Holland pholland@nacha.org © 2013 NACHA — The Electronic Payments Association. All rights reserved. No part of this material may be used without the prior written permission of NACHA. This material is not intended to provide any warranties or legal advice and is intended for educational purposes only.