Operating Rules Mandate - EFT and ERA
Role of CAQH CORE | Getting Involved with CAQH CORE | Education and Outreach | Contacts
Draft CAQH CORE EFT & ERA Operating Rules
The Complete Set of Draft Phase III CORE EFT & ERA Operating Rules (version for Final CORE Membership Vote), developed in 2011 by CORE Participants with industry input, includes five draft operating rules. To further support the CORE Guiding Principles and align with Federal efforts, the draft CAQH CORE EFT & ERA Operating Rules have been updated for the final CORE vote. No substantive revisions were made to the draft rules and the rule requirements remain unchanged; the non-substantive updates include:
- Removal of references to voluntary CORE Certification (e.g., A CORE-certified entity must )
- Adjusted Conformance Requirements section of each rule to clarify CMS will determine conformance with the Federal mandates
- Appropriate references to the January 2012 Interim Final Rule with Comment (CMS-0024-IFC): Administrative Simplification: Adoption of Standards for Health Care Electronic Funds Transfers (EFTs) and Remittance Advice
Links to the individual draft rules are available below.
- Draft EFT Enrollment Data Rule
- Draft ERA Enrollment Data Rule
- Draft Uniform Use of CARCs and RARCs (835) Rule
- Draft EFT & ERA Reassociation (CCD+/835) Rule
- Draft Claim Payment/Advice (835) Infrastructure Rule
Status of Mandated EFT & ERA Operating Rules: Draft CAQH CORE EFT & ERA Rules Recommended by NCVHS
On March 23, 2011 NCVHS sent a letter to the Secretary of HHS making a recommendation to name "CAQH CORE in collaboration with NACHA The Electronic Payments Association as the candidate authoring entity for operating rules for all healthcare EFT and ERA transactions..."
On August 1, 2011, CAQH CORE and NACHA jointly submitted a letter to the Co-Chairs of the National Committee on Vital and Health Statistics (NCVHS) Subcommittee on Standards, an advisory body to the Department of Health and Human Services (HHS), to provide an update on progress developing healthcare operating rules for EFT & ERA, including links to draft rules.
On December 7, 2011, NCVHS sent a letter to Secretary Sebelius, HHS, making a recommendation the Secretary adopt the set of five operating rules submitted to NCVHS by CAQH CORE and NACHA, conditional on the authoring entities making certain revisions to the proposed operating rules. The conditions included:
- The Secretary ensures that all references to the CORE Certification requirement are removed from any documents that are adopted as mandatory by HHS, and that the CAQH CORE website be similarly updated and amended.
- The Secretary work with CAQH CORE to develop a naming convention that consistently and easily identifies the transaction to which the rule applies.
CAQH CORE is committed to working with the industry to identify optimal packaging of the operating rules and will update the draft operating rules and CAQH CORE website accordingly.
Coordination with Financial Services Industry: NACHA's Proposed Enhancement to NACHA Operating Rules Due to Healthcare Use of EFT
The financial services industry maintains its own set of operating rules (NACHA Operating Rules and Guidelines) which govern the ACH Network. The NACHA Operating Rules are separate and distinct from the CAQH CORE Operating Rules and address the use of the electronic funds transfer (EFT) standard. Only financial institutions are formal members of NACHA The Electronic Payments Association and can directly decide on the NACHA Operating Rules content.
CAQH CORE and NACHA have been working in partnership as the healthcare industry moves to adopt the industry-neutral EFT and a set of EFT & ERA healthcare operating rules. In March of 2012, NACHA issued a Request for Comment (RFC) on potential amendments to the NACHA Operating Rules with comments due by April 27th. The purpose of these amendments is to address both enhancements requested by the healthcare industry to improve the delivery of remittance information contained in EFT payments transmitted via the ACH Network, as well as other enhancements identified by the NACHA membership.
CAQH CORE submitted comments to NACHA for its consideration based on feedback from CORE Participants on the RFC. In addition, the CAQH CORE Rules Work Group is holding a call on May 18th, 2012 on which NACHA staff will be available to provide insight and rationale for the proposed enhancements and answer questions on the framework of the ACH Network as it relates to the proposed enhancements. This open exchange will assist healthcare and financial services to further ensure alignment, coordination and simplification; as well as consider next steps. For more information on the CAQH CORE comments on the NACHA RFC, please email CORE@caqh.org.
Role of CAQH CORE for EFT & ERA
NCVHS recommended to HHS that CAQH CORE and NACHA The Electronic Payments Association, be the authoring entities for the second set of Federally mandated operating rules for the electronic funds transfer (EFT) and electronic remittance advice (ERA) transactions. The draft CAQH CORE EFT & ERA Operating Rules have been recommended by NCVHS to HHS to meet ACA operating rule requirements for the two transactions.
For more information on the role of CAQH CORE, email CORE@caqh.org.
Getting Involved with CORE for EFT & ERA
CAQH CORE continues to welcome participants from all healthcare stakeholder groups to contribute to future operating rule development. There are multiple ways to become involved in the development of operating rules that drive the business of healthcare:
- Your organization can join CORE to participate directly in the rule development process,
- Achieve voluntary CORE Certification, and/or
- Endorse CORE.
As CAQH CORE continues to evolve its rule development processes, entities are encouraged to submit ideas for future operating rules or modifications to CORE@caqh.org.
Interested stakeholders are encouraged to contact CAQH CORE to learn more about how to become a CORE Participant at CORE@caqh.org.
View the list of CORE Participating Organizations.
Education and Outreach
CAQH CORE is committed to educating the industry on the value of operating rules and how they build on standards. The scope of the CORE rules to date reflects the realities of how health plans and providers can use electronic transactions to move the industry forward while supporting current operations. The CORE rule development and voting processes are transparent and inclusive, and highlight the roles of those who need to implement the rules: health plans, clearinghouses/vendors, and providers.
CAQH CORE holds frequent education sessions with partners such as WEDI, associations, and Medicaid workgroups. Presentations often include speakers from organizations that have already implemented the rules. Additionally, CAQH CORE holds monthly, industry-wide free Town Hall calls to provide both non-CORE and CORE participants with an informal update on CAQH CORE activities, including activities related to the ACA Section 1104 Administrative Simplification provisions (e.g. status of regulations, CORE Rule development, etc.).
View the complete list of CORE Education Events (including copies of past sessions)
View the complete list of CAQH CORE Town Hall Calls (including recordings of past sessions)
Interested in having CAQH CORE present at your event/organization? Email CORE@caqh.org.
Role of CAQH CORE for EFT & ERA
For more information about the mandated operating rules process contact CAQH CORE at CORE@caqh.org.
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