CMS recently issued an interim final rule to adopt EFT/ERA operating rules, one of a series of such rules mandated under the Affordable Care Act to make HIPAA transactions more uniform, and the AHA gave its positions in a comment letter.
The operating rules will alleviate the “reassociation” problem of matching the EFT to the related ERA, “especially when these distinct transactions are submitted on different dates and take different paths in getting to the provider,” the AHA noted. “Successful reassociation requires the use of the trace number segment (TRN) on both the EFT and ERA, along with several other related data elements. Overcoming the reassociation problem is a very positive step and will further drive economies of scale as more providers find that they can confidently rely on automation to match the ERA to the EFT. We urge CMS to take the lead in providing educational and instructional materials that clarify the correct use of the reassociation data reported on both the EFT and ERA.”
The association also recommends that while major new operating rules or substantial revisions should go through the normal notice and comment processes, technical corrections, clarifications and updates should be fast-tracked. Further, while noting that the interim final rule prohibits protected health information from being included in the EFT, there remains the need for guidance on PHI for other financial transactions such as ATMs and debit/credit cards. “The AHA urges HHS to address the PHI issue as it pertains to commonplace financial instruments as well as emerging applications found in mobile devices.”
Text of the AHA’s comment letter on the interim final rule for EFT/ERA operating rules is available here.