Healthcare providers interested in cost savings and other benefits are converting to electronic payments at a steady clip. In 2014, the ACH Network moved more than 149 million healthcare Electronic Funds Transfers (EFTs), transferring about $876.6 billion in claim payments from health plans to providers. During the same period, it is estimated that the healthcare industry saved approximately $295 million by using the healthcare EFT standard and Electronic Remittance Advice (ERA).

But what if a provider has received an EFT payment with no corresponding ERA and doesn’t recognize the sending organization? How is the sender determined? Unfortunately when a provider does not receive the associated ERA and cannot recognize the originator of the transaction, the provider must follow-up with the bank and the health plan—often with numerous phone calls.

Populating the Company Name Field of the CCD+Addenda

For the healthcare EFT standard CCD+Addenda, the NACHA Operating Rules require that “the Company Name field must contain the name of the Health Plan originating the CCD, or, where an organization is self-insured, the name of the organization’s third-party administrator that is recognized by the Healthcare Provider and to which the Health Care Provider submits its claim.” 

Using the name of the clearinghouse or vendor instead of the health plan or third-party administrator does not comply with the requirements of the NACHA Operating Rules. If the originator of the healthcare EFT standard transactions is not populating the company name field in accordance with the NACHA Operating Rules, the provider’s financial institution can file a Report of Possible Rules Violation through NACHA’s National System of Fines. 

The goal of the National System of Fines is to ensure compliance with the NACHA Operating Rules and to have all parties correct possible formatting errors. If corrections are not made and the originator is found to be in violation of the NACHA Operating Rules, fines can be levied against the Originating Depository Financial Institution (ODFI), which may then pass those charges along to the originator. Fines range from $1,000 to $500,000, depending on the classification and severity of the violation.

Determining the Payment Originator

In those instances when the company name field is not populated correctly and the name of the originator of the CCD+Addenda is unknown, some financial institutions recommend that providers contact NACHA directly for assistance. However, as the rulemaking body for the ACH Network, NACHA is not a payments processor and does not possess detailed information on individual payments. NACHA staff does not have access to any information that can identify the originator of the healthcare EFT transaction and will recommend that the providers contact their financial institution for assistance.

Here are some helpful tips for healthcare providers that need to work with their financial institution to identify the EFT originator:

*Contact your financial institution and give them the account number, the deposit date, and the amount of the transaction. 

*Advise the bank that you need assistance in identifying the originator of the transaction.

*Ask the bank to contact the ODFI of the transaction.

*The bank will need to give the ODFI the ACH trace number of the transaction (which is different from the TRN Reassociation Trace Number) to receive the name of the originator and a contact phone number.

The 2013 CAQH U.S. Efficiency Index estimates that the healthcare industry can save $1.98 per claims payment using the healthcare EFT standard and ERA, thanks to the automated reconciliation of the payment with the ERA and the auto-posting of both the EFT and ERA.     

It is important to both health plans and providers that the originator of the healthcare EFT is easily and correctly identified in the healthcare EFT standard format and that associated ERA or explanations of benefits are sent in a timely manner to eliminate the need for manual intervention and time-consuming follow-up.

Priscilla Holland is the Senior Director of Healthcare & Industry Verticals for NACHA--The Automated Payments Network.

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