Frequently Asked Questions - VII. CAQH CORE Payment & Remittance ERA Enrollment Data Rule

No. Section 4.5 of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 specifies that “If a health plan or its agent does not use a paper-based manual method and process to collect the CORE-required Maximum ERA Enrollment Data Set as of the compliance date specified in any Federal regulation adopting this CORE Rule, it is not required by this rule to implement a paper-based manual process on or after the compliance date.”

NOTE: The CAQH CORE Payment & Remittance ERA Enrollment Data Rule addresses electronic and paper-based collection and submission of the enrollment data. It does not specify the health plan’s internal enrollment process.

Section 4.3.2 of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 requires that the CORE-required Maximum ERA Enrollment Data Set be used without revision or modification, and that the order of the data conforms to the flow, format, and data set (including data element descriptions) established in Table 4.2-1 of the rule. This requirement applies to both electronic enrollment data collection forms and manual paper-based forms, should a health plan or its agent offer a paper-based data collection process. To comply with the CAQH CORE Payment & Remittance ERA Enrollment Data Rule requirements, a health plan (or its agent or a vendor offering ERA) must not modify or vary the CORE ERA enrollment form template and ERA enrollment forms must follow the flow, format, and data set as specified in the rule.

The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 establishes a maximum set of data elements for both paper and electronic ERA enrollment data collection and submission. This maximum set of CORE-required ERA Enrollment Data Elements is specified in Table 4.2-1 of the rule, organized by categories of information referred to as “Data Element Groups”. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule, Section 4.3 and its subsections specify the requirements for how the CORE-required Maximum ERA Enrollment Data Elements must be presented in both paper and electronic based ERA enrollment forms. Specifically, the rule requires that health plans (or their agents or vendors offering ERA) use the format, flow, and data set (including data element descriptions) as given in Table 4.2-1. Additionally, all CORE-required ERA Enrollment data elements (including DEGs) must appear in the same order as they appear in Table 4.2-1.

The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 establishes a maximum set of data elements for both paper and electronic ERA enrollment. This maximum set of CORE-required ERA Enrollment Data Elements is specified in Table 4.2-1 of the rule. Section 4.3 and its subsections describe how the CORE-required Maximum ERA Enrollment Data Elements must be presented.

Also, the CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not preclude health plans (or their agents) from collecting additional data elements in locations beyond the ERA enrollment form for other purposes beyond ERA enrollment. Additionally, the CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not prohibit health plans and their agents from adding capabilities to the electronic ERA enrollment method designed to improve functionality and ensure data integrity and comprehensiveness. Examples of functional and data improvements that may be added to the electronic submission tool include:

• Use of drop-down selection lists and/or radio buttons to respond to each CORE-required Data Element or Sub-element
• Requiring re-entry of key data to ensure accuracy
• Inclusion of a context-specific “Help” button to display a window that provides a detailed description of the CORE-required Data Element or other guidance, e.g., data format, etc.
• Enabling the end user to assign nicknames to certain data fields to better manage his/her data
• Displaying all data entered to the end user for final review/correction prior to actual “submission”

Yes. The CAQH CORE Payment & Remittance EFT Enrollment Data Rule vPR.1.0 and CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR.1.0 establish a maximum set of data elements to be included on enrollment forms for EFT and ERA, as well as a required flow and format for presentation of the data elements on the form. The two rules were developed independent of each other as some health plans enroll providers separately for EFT and ERA while other combine the enrollments.

The CAQH CORE Enrollment Data Rules do not require or prohibit entities from creating a single form for the purposes of both EFT and ERA enrollment, as long as the format, flow, and data set (including data element descriptions) are used as specified in CAQH CORE Payment & Remittance EFT Enrollment Data Rule Table 4.2-1 and CAQH CORE Payment & Remittance ERA Enrollment Data Rule Table 4.2-1. Section 4.5 of the CAQH CORE EFT & ERA Enrollment Data Rules also specify the timeframe for converting existing paper-based EFT and ERA enrollment forms to comply with the rules.

Yes. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 establishes a maximum set of data elements to be included on an ERA enrollment form, as well as a required flow and format for presentation of the data elements on the form. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not require or prohibit entities from using an inclusive form for the purposes of ERA Enrollment, as long as the format, flow, and data set (including data element descriptions) are used as given in CAQH CORE Payment & Remittance ERA Enrollment Data Rule, Table 4.2-1, CORE-required Maximum ERA Enrollment Data Set. Section 4.5 of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule specifies the timeframe for converting existing paper-based enrollment forms to comply with the rule.

NOTE: Section 4.4 of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule also requires all health plans, and their agents or vendors offering ERA enrollment, to “implement and offer to any trading partner (e.g., a healthcare provider) an electronic method (actual method to be determined by health plan or its agent) and process for collecting the CORE-required Maximum ERA Enrollment Data Set.”

Yes. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 establishes a maximum set of data elements to be included on an ERA enrollment form, as well as a required flow and format for presentation of the data elements on the form. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not require or prohibit entities from using an inclusive form for the purposes of ERA Enrollment, as long as the format, flow, and data set (including data element descriptions) are used as specified in rule. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule specifies the timeframe for converting existing paper-based enrollment forms to comply with the rule.

NOTE: The CAQH CORE Payment & Remittance ERA Enrollment Data Rule also requires all health plans, and their agents or vendors offering ERA enrollment, to “implement and offer to any trading partner (e.g., a healthcare provider) an electronic method (actual method to be determined by health plan or its agent) and process for collecting the CORE-required Maximum ERA Enrollment Data Set.”

No. Section 4.3.1 of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 requires that health plans provide instructions online for how providers can determine the status of the enrollment. The ERA enrollment form must include a section outlining how to access these online instructions. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not require that that the status of enrollment must be able to be determined via online tool.

The CORE-required Maximum ERA Enrollment Data Set includes eight Data Element Groups (DEGs). A DEG may be designated as required or optional for data collection. Additionally, within each DEG, Individual Data Elements may be designated as required or optional for data collection.

When a DEG is designated as required:

• The health plan must collect all Individual Data Elements within the DEG that are designated as required.
• The health plan may elect not to collect any Individual Data Elements within the DEG that are designated as optional.

When a DEG is designated as optional:

• The health plan may elect not to include this optional DEG for collection on the ERA Enrollment Form.
• However, if the health plan chooses to collect this optional DEG, the health plan must collect all Individual Data Elements within the DEG that are designated as required; the health plan may elect not to collect any Individual Data Elements within the optional DEG that are designated as optional.

No. If a health plan chooses to collect an optional DEG:

• The health plan must collect all Individual Data Elements within the optional DEG that are designated as required.
• However, the health plan may elect not to collect any Individual Data Elements within the optional DEG that are designated as optional.

Not collecting an Individual Data Element identified as optional is not prohibited by the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 requirements for the CORE-required Maximum ERA Enrollment Data Set. However, the CAQH CORE Payment & Remittance ERA Enrollment Data Rule requires that the following Individual Data Elements must be collected during the ERA Enrollment process:

• All required Individual Data Elements within required DEGs
• All Individual Data Elements designated as required within optional DEGs, if the health plan chooses to collect the optional DEG.

NOTE: The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not prevent a health plan from pre-populating, or auto-populating, the form with known data (for the provider to confirm or change), but the required Individual Data Elements must still be collected during the process.

Section 4.4 of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 requires all health plans to offer an “electronic safe harbor” enrollment method/process for collecting the CORE-required Maximum ERA Enrollment Data Set. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule requires that the following Individual Data Elements must be included in the electronic enrollment method:

• All required Individual Data Elements within required DEGs
• All Individual Data Elements designated as required within optional DEGs, if the health plan chooses to collect the optional DEG.

No. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0, Section 4.3.2, Master Template for Electronic Enrollment, requires that a web-based method of enrollment is restricted “only to the extent that the flow, format and data set including data element descriptions established by this rule must be followed.” The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not include any language surrounding pagination or other contiguity of the data. Therefore, a web-based enrollment method with data elements on different pages would be compliant with the rule requirements.

No. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 establishes a maximum set of data elements to be collected by the health plan from the provider for ERA enrollment, as well as a required flow and format for the data elements on a web-based or paper-based enrollment form. It does not address data elements in the X12 v5010 835 ISA and GS control segments. These data elements are outside the scope of the CAQH CORE Rule, and would need to be collected from the provider external to the ERA Enrollment process.

No. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0, Master Template for Electronic Enrollment, requires that a web-based method of enrollment is restricted “only to the extent that the flow, format and data set including data element descriptions established by this rule must be followed.” The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not include any language surrounding pagination or other contiguity of the data. Therefore, a web-based enrollment method with data elements on different pages would be compliant with the rule requirements.

Yes. CAQH CORE has published an Excel-based version of Table 4.2-1, CORE-required Maximum ERA Enrollment Data Set. The Excel Workbooks are available on the CAQH CORE website. Beyond this Excel document and the table in the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0, there are no other available data file examples of the CORE-required Maximum ERA Enrollment Data Set.

No. The reference in the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 to a “safe harbor” does not mean that health plans must support the CAQH CORE Connectivity Safe Harbor in the CAQH CORE Connectivity Rule vC2.2.0 for collection of the CORE-required Maximum ERA Enrollment Data Set. Section 4.4, CAQH CORE Electronic Safe Harbor for ERA Enrollment, of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule requires all health plans to offer an “electronic safe harbor” enrollment method/process for collecting the CORE-required Maximum ERA Enrollment Data Set. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not specify the electronic method that health plans must use to fulfill the safe harbor requirement.

While the CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not require health plans to do so, health plans may choose to use the CAQH CORE Connectivity Safe Harbor in the CAQH CORE Connectivity Rule vC2.2.0 to fulfill the CAQH CORE Electronic Enrollment Safe Harbor. The CAQH CORE Connectivity Rule is payload agnostic and thus can carry both X12 and non-X12 administrative transaction payloads. The CAQH CORE Connectivity Rule vC2.2.0 specifies how to enumerate non-X12 payloads in the PayloadType field.

No. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 establishes a maximum set of data elements for both paper and electronic ERA enrollment as well as how the CORE-required Maximum ERA Enrollment Data Elements must be presented in both paper and electronic based ERA enrollment forms The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not establish a required timeframe for processing a provider’s ERA Enrollment.

NOTE: Section 4.2, CORE-required Maximum ERA Enrollment Data Elements, of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule requires the health plan to “develop and make available to the healthcare provider (or its agent) specific written instructions and guidance for the healthcare provider (or its agent) when providing and submitting the data elements in Table 4.2-1.”

The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not specify the exact wording for the instructions and guidance that must be provided by the health plan. In anticipation of provider questions, the health plan could choose to describe its expected timeframe for processing enrollments in these instructions.

Section 4.5 of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 specifies a time frame for health plans to convert all paper-based ERA enrollment forms relative to the compliance date for any Federal regulation that adopts the rule for mandatory implementation. Specifically the rule states: “Not later than the date that is six months after the compliance date specified in any Federal regulation adopting this CORE Operating Rule, a health plan or its agent that uses a paper-based form to collect and submit the CORE-required Maximum ERA Enrollment Data Set must convert all its paper-based forms to comply with the data set specified in this rule.”

NOTE: The CAQH CORE Payment & Remittance ERA Enrollment Data Rule requirement applies only if a health plan, or its agent or vendor offering ERA enrollment, has an existing paper-based enrollment form or chooses to use a paper-based form. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not require health plans to use a paper-based enrollment form if they do not currently do so. However, an electronic method for collecting and submitting the enrollment data elements is required.

In August 2012, HHS issued an Final Rule that adopts all of the CAQH CORE Payment & Remittance Operating Rules to fulfill the Federal mandate under ACA Section 1104, with the exception of rule requirements pertaining to use of Acknowledgements. Per ACA Section 1104, the compliance date for the ACA-mandated EFT & ERA operating rules is January 1, 2014. The CAQH CORE Payment & Remittance ERA Enrollment Data Rules requires health plans to modify their paper-based enrollment forms to conform to the CORE-required Maximum ERA Enrollment Data Set no later than six months after the January 1, 2014 Federal compliance date.

No. Verifying the accuracy of the data collected from the provider during the ERA enrollment process is out of scope for the CAQH CORE Payment & Remittance Operating Rules. The policies and methods that a health plan uses to verify accuracy of data are business decisions on the part of the health plan or its agent or vendor offering ERA enrollment.

Yes. A health plan (or its agent or vendor offering ERA enrollment) must collect all Individual Data Elements per the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 requirements, including those for which the health plan has no business need.

The CORE-required Maximum ERA Enrollment Data Elements were identified after substantial industry research and analysis to compare ERA enrollment forms from across the industry. CAQH CORE Participants agreed that these data elements represented the maximum set of data elements required for successful ERA enrollment. The CORE-required Maximum ERA Enrollment Data Set includes eight Data Element Groups (DEGs) designated as required or optional for data collection. Per the CORE-required Maximum ERA Enrollment Data Elements, of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule, the following Individual Data Elements must be included on either a paper-based or electronic enrollment form:

• All required Individual Data Elements within required DEGs
• All Individual Data Elements designated as required within optional DEGs, if the health plan chooses to collect the optional DEG.

No. The CAQH CORE Payment & Remittance EFT Enrollment Data Rule vPR.1.0 and CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR.1.0 establish a maximum set of data elements to be included on an EFT and/or ERA enrollment form, as well as a required flow and format for presentation of the data elements on the form. The CAQH CORE EFT & ERA Enrollment Data Rules do not address whether health plans can make provider enrollment to receive healthcare EFT contingent on the provider also enrolling to receive the X12 v5010 835 ERA, or vice versa. Such a requirement is a health plan’s individual business decision.

Section 4.3 of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 requires health plans “to use the format, flow and data set including data element descriptions in Table 4.2-1 as the CORE Master ERA Enrollment Submission form” for both paper-based and electronic ERA enrollment methods. The intent of the reference to “format, flow, and data set” is:

• “Flow” means the order/sequence of the data elements in Table: 4.2-1
• “Data Set” is the set of elements specified in Table: 4.2-1
• “Format” refers to the Data Type and Format as specified in Table: 4.2-1 (e.g., alphanumeric, 15 characters for Zip Code).

The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 does not define a specific format(s) that constitutes an electronic method and process for collecting the CORE-required Maximum ERA Enrollment Data Set.

CAQH CORE does not provide a definition of “electronic” methods specific to implementation of the CAQH CORE Operating Rules. Rather, CAQH CORE has relied on various HIPAA regulations to do so for the industry. Currently, there are many ways entities can implement an “electronic” collection method. In the broader context of the mission and vision of CAQH CORE, the goal is to assist the industry to adopt uniform and consistent automated electronic processes to reduce costs and build efficiencies.

CMS is the HHS designated authority on any decisions regarding interpretation, implementation, and enforcement of the regulations adopting the HIPAA and ACA Administrative Simplification standards and provisions. As the regulatory authority, the determination of what constitutes an “electronic” method for collecting the CORE-required Maximum ERA Enrollment Data Set must be made by the CMS Division of National Standards (DNS). The January 2013 HHS HIPAA Privacy and Security omnibus final rule includes a definition of “electronic media,” and CAQH CORE has asked CMS DNS to provide further guidance to the industry on the regulatory language, and what constitutes an “electronic” method.

The CAQH CORE Enrollment Data Rules do not prohibit entities from creating a single form for the purposes of both EFT and ERA enrollment. A combined EFT and ERA enrollment form must contain all the required Data Element Groups (DEGs) and required Individual Data Elements from Table: 4.2-1, CORE-required Maximum EFT/ERA Enrollment Data Set, in CAQH CORE Payment & Remittance EFT and ERA Enrollment Data Rules. NOTE: Entities are not required to repeat DEGs that are identical in both enrollment data rules (e.g., DEG1).

Although the CAQH CORE Enrollment Data Rules do not explicitly outline the flow and format for a combined EFT and ERA enrollment form, DEGs unique to either of the CAQH CORE Enrollment Data Rules would need to be collected using the same general flow and format. For example, “Financial Institution Information” (DEG7 in the CAQH CORE Payment & Remittance EFT Enrollment Data Rule) and “Electronic Remittance Advice Information” (DEG7 in the CAQH CORE Payment & Remittance ERA Enrollment Data Rule) are both required for collection on a combined EFT and ERA enrollment form. Both DEGs would be collected after DEGs 1 through 6 in the CAQH CORE Payment & Remittance Enrollment Data Rules, and before “Submission Information”, DEG 10 in the CAQH CORE Payment & Remittance ERA Enrollment Data Rule.

No. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 does not explicitly define what a health plan must collect for the Sub-element “Email Address” when a provider does not have an email address. However, Section 4.2, CORE-required Maximum ERA Enrollment Data Elements requires a health plan to “develop and make available to the healthcare provider (or its agent) specific written instructions and guidance for the healthcare provider (or its agent) when providing and submitting the data elements in Table 4.2-1.” The health plan could, in these instructions, describe what the provider should enter if the provider does not have an email address (e.g., “If you do not have an email address, please leave the field blank,” or “If you do not have an email address, please enter ‘NONE’,” etc.).

Yes. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 provides a uniform and consistent maximum set of data elements that can be used by any health plan (or its agent/vendor offering ERA enrollment) for the purposes of enrolling any healthcare provider to receive claim payment electronically. This data set is the same for all providers and all health plans (or their agents/vendors); the CAQH CORE Payment & Remittance ERA Enrollment Data Rule, therefore, can support approaches that are designed to enroll all providers with all plans (i.e., mass enrollment).

Section 4.2 of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule requires a health plan (or its agent/vendor offering ERA enrollment) to “develop and make available to the healthcare provider (or its agent) specific written instructions and guidance for the healthcare provider (or its agent) when providing and submitting the data elements”. A clearinghouse, or other intermediary, could include in these instructions specific to the health plans for which it is authorized to collect enrollment data.

The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not address the functionality or capability of an ERA enrollment system or process, which may include other data functions/capabilities beyond the collection of the CAQH CORE-required Maximum ERA Enrollment Data Set. A clearinghouse, or other intermediary, that conducts mass enrollment may include data fields in its enrollment process to collect information such as with which health plans providers want to enroll (specific to the health plans for which the clearinghouse is authorized to collect such provider enrollment data). Such a data field could be included in the enrollment process prior to or after collection of the CORE-required Maximum ERA Enrollment Data Set.

The CAQH CORE Payment & Remittance ERA Enrollment Data Rule also permits clearinghouses, and other entities conducting ERA enrollment, to include other functionalities in the enrollment process (e.g., requiring a username/password to log on to the health plan’s website to begin the enrollment process, use of a mouse hover to display supplemental information about data elements, etc.).

Per the HIPAA Administrative Simplification provisions, as of May 2008, HIPAA covered entities must use the National Provider Identifier (NPI) only to identify a group or individual as a HIPAA covered provider in the HIPAA transaction standards. A Taxpayer Identification Number (TIN), e.g., Social Security Number (SSN) or Employer Identification Number (EIN), can only be used when identifying a HIPAA covered provider as a tax payer.

These requirements do not apply to providers that are not HIPAA-covered as non-HIPAA covered providers are not required to obtain and use an NPI. Per CMS, a non-HIPAA covered provider that does not have an NPI should be identified in the HIPAA transaction standards by its SSN or EIN as its Primary Identifier in standard transactions designed to capture a Primary and a Secondary Identifier for a health care provider or by one of the qualifiers listed in the Implementation Guides to capture a single identifier for a health care provider.

The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 requires inclusion of both NPI and TIN as “Provider Identifier” and “Account Number Linkage to Provider Identifier” sub-elements to allow for enrollment of a non-HIPAA covered provider that does not have an NPI.

The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 includes the following requirements for collection of National Provider Identifier (NPI) and Taxpayer Identification Number (TIN) within the CORE-required Maximum ERA Enrollment Data Set:

• DEG2: Provider Identifiers Information collects information related to the enrolling provider identified in DEG1: Provider Information. DEG2 requires health plans (or their agent/vendor offering EFT enrollment) to collect a “Provider Identifier” which must be the identification number, NPI or TIN for non-HIPAA covered providers, for the legal entity reported under the “Provider Name” Data Element in DEG1: Provider Information.
• DEG7: Financial Institution Information collects information related to the Receiving Depository Financial Institution (RDFI) where the provider maintains the account to which claim payments are to be deposited. DEG7 requires health plans (or their agent/vendor offering ERA enrollment) to collect an “Account Number Linkage to Provider Identifier” which must be the identification number, NPI or TIN for non-HIPAA covered providers, linked to the provider’s RDFI account.

The CAQH CORE Payment & Remittance ERA Enrollment Data Rule addresses the data to be collected during ERA enrollment; it does not specify requirements for health plans to implement a certain process after the data is collected. Beyond the data collection requirements, how a health plan groups claim payments to providers is a business decision and contract issue to be negotiated between the health plan and its provider trading partners.

Section 4.2 of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule also requires health plans to “develop and make available to the healthcare provider (or its agent) specific written instructions and guidance for the healthcare provider (or its agent) when providing and submitting the data elements”. The health plan could include in these instructions a description of its entity-specific process to reach agreement on payment grouping.

Yes. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 provides a uniform and consistent maximum set of data elements that can be used by any health plan (or its agent or vendor) for the purposes of enrolling any healthcare provider (or its agent) to receive claim payment via ERA. This maximum set of data elements is specified in the CAQH CORE Payment & Remittance ERA Enrollment Data Rule, organized by categories of information referred to as “Data Element Groups” (DEGs).

As part of DEG2: Provider Identifiers Information (DEG2), a health plan (or its agent or vendor offering ERA enrollment) can choose to collect an optional Other Identifier(s). The Other Identifier(s) Individual Data Element allows a health plan to collect proprietary provider identifiers specific to its individual business needs. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not specify a data type or format for this identifier. Therefore, a health plan can use the Optional Identifier(s) data element to collect identification numbers for all service locations for which the enrolling provider wants to receive ERA.

Section 4.2 of the CAQH CORE-required Maximum ERA Enrollment Data Elements, in the CAQH CORE Payment & Remittance ERA Enrollment Data Rule requires a health plan to “develop and make available to the healthcare provider (or its agent) specific written instructions and guidance for the healthcare provider (or its agent) when providing and submitting the data elements.” A health plan can include guidance in these instructions for how providers should complete the Other Identifier(s) data element.

The CAQH CORE Payment & Remittance ERA Enrollment Data Rule also permits health plans, and their agents or vendors offering ERA enrollment, to include other functionalities in the enrollment process improve functionality and ensure data integrity and comprehensiveness. For example, a health plan may use a drop-down list to identify the optional service locations (via their proprietary identifiers) for which the providers can enroll to receive ERA.

As specified in Section 3.1, When the Rule Applies, the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 applies “when a health plan or its agent is enrolling a healthcare provider (or its agent)” to receive claim payment electronically via the Healthcare ERA Standards. As referenced, a “provider agent” is an entity that that has been designated and sufficiently authorized by the provider to receive ERA payments on the provider’s behalf. DEG4: Provider Agent Information in the CORE-required Maximum ERA Enrollment Data Set enables a health plan (or its agent/vendor offering ERA enrollment) to collect information about the provider’s designated agent.

No. Section 4.3.1, Master Template for Manual Paper-Based Enrollment of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 requires a health plan (or its agent/vendor offering ERA enrollment) to include the following items on its paper-based ERA enrollment form:

• Specific written instructions and guidance for completing and submitting the enrollment form
• A number to fax and/or a U.S. Postal Service or email address to send the completed form
• Contact information for the health plan, specifically a telephone number and/or email address to send questions
• Authorization language for the provider to read and consider
• A section that outlines how the provider can access online instructions for how to determine the status of the ERA enrollment
• Clear labels for any appendix describing its purpose as it relates to the provider enrolling in ERA

The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not specify any requirements regarding pagination. A health plan may choose to include the above additional items on a single page of the enrollment form or on a separate page at the health plan’s discretion. NOTE: To conform to the flow and format requirements specified in the CAQH CORE Payment & Remittance ERA Enrollment Data Rule, the above items cannot appear within or between the Maximum Enrollment Data Elements.

NOTE: The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not require health plans to offer a paper-based enrollment form. However, an electronic method for collection and submission of the CORE-required Maximum ERA Enrollment Data Set must be offered. If a health plan chooses to also offer a paper-based enrollment form it must conform to all applicable CAQH CORE Payment & Remittance ERA Enrollment Data Rule requirements.

Data Element Group (DEG) 8: Submission Information in the CORE-required Maximum ERA Enrollment Data Set includes as a required Individual Data Element “Authorized Signature”. This data element allows a health plan (or its agent/vendor offering ERA enrollment) to collect the “signature of an individual authorized by the provider or its agent to initiate, modify or terminate an enrollment”. As specified in Table 4.2-1, a health plan (or its agent/vendor offering ERA enrollment) can require this signature to be submitted either electronically or written (i.e., “wet”). It is the health plan’s individual business decision what method it chooses to use to obtain the authorizing signature.

Section 4.2 of the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 requires a health plan to “develop and make available to the healthcare provider (or its agent) specific written instructions and guidance for the healthcare provider (or its agent) when providing and submitting the data elements in Table 4.2-1.” Depending on what method the health plan chooses to obtain the authorized signature, the health plan could provide guidance to the provider in the instructions for how providers should submit the signature (e.g., if the health plan chooses to include “Written Signature of Person Submitting Enrollment” in its electronic enrollment method, the health plan could instruct the provider how to deliver the required wet signature prior to/along with/after completion of the electronic enrollment in ERA).

As specified in Section 3.4, CORE Process for Maintaining CORE-required Maximum EFT Enrollment Data Set, of the CAQH CORE Payment & Remittance EFT Enrollment Data Rule vPR.1.0 and CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR.1.0, the CAQH CORE-required Maximum EFT & ERA Enrollment Data Sets are reviewed and updated on an annual basis. Section 3.4 in the CAQH CORE Payment & Remittance EFT and ERA Enrollment Data Rules requires that the first review of the enrollment data sets commence one year after the rules were adopted into federal regulation. This first review occurred in 2014.

• Limited Reviews: Occur biennially and consider only non-substantive adjustments to the Enrollment Data Sets; occur on an alternating schedule with Comprehensive Reviews (next Limited Review is in 2016)
• Comprehensive Reviews: Occur biennially and consider both substantive and non-substantive adjustments to the Enrollment Data Sets; occur on an alternating schedule with Limited Reviews (next Comprehensive Review is in 2017)

NOTE: Adjustments pertaining to rule language and requirements beyond the CAQH CORE-required Maximum EFT & ERA Enrollment Data Sets are out of scope for the CAQH CORE EFT & ERA Enrollment Data Maintenance Process.

In keeping with the CAQH CORE multi-stakeholder, collaborative and transparent rule development process, participation in the CAQH CORE Enrollment Data Task Group is open to representatives from any CORE Participating Organization. There is no limit to the number of representatives that a CORE Participating Organization can assign to the Task Group. Individuals with knowledge of the business processes and workflows for EFT and ERA enrollments are strongly encouraged to join the Task Group. Interested participants can send their name, title, organization name, email address, and telephone number to core@caqh.org.

The CAQH CORE Enrollment Data Task Group uses a set of Enrollment Data Evaluation Criteria to evaluate potential substantive adjustments to the CORE-required Maximum EFT & ERA Enrollment Data Sets. When submitting potential substantive adjustments for Task Group consideration, stakeholder entities will be required to confirm that their submission meets at least four of the seven criteria listed below:

1. Supports the vision of the CAQH CORE Enrollment Data Rules to move the industry toward a uniform, standard maximum set of required EFT and ERA enrollment data elements
2. Promotes EFT and ERA enrollment efficiency (e.g., reduction in staff time and resources required to complete enrollment) and increases provider adoption by reducing the range of enrollment information requested and variation in terms used to collect the same/similar information
3. Does not result in addition of data elements that are semantic variations of existing data elements; i.e., data elements must collect unique and distinctly separate information
4. Meets a demonstrated, new or current industry-wide multi-stakeholder business need not addressed by the existing Enrollment Data Set
5. Ensures collection of key items needed to fully automate both claims payment and remittance advice posting processes
6. Balances return on investment (ROI) and industry-wide benefit against the significant lift required for health plans or agents to revise enrollment systems and paper-based forms and for providers to provide the data
7. Consistent with CAQH CORE Guiding Principles

In addition to alignment with the above Evaluation Criteria, the Enrollment Data Task Group’s policy is to collect Supporting Information including a Business Case and any applicable Supporting Data for each submitted potential substantive adjustment to the CORE-required Maximum EFT & ERA Enrollment Data Sets.

HIPAA-covered entities will need to update their EFT and ERA enrollment forms/systems to ensure conformance with any substantive adjustments applied to the data sets as a result of a Comprehensive Review. Per the CAQH CORE EFT & ERA Enrollment Data Sets Maintenance Process, a health plan, or its agent offering EFT and/or ERA enrollment, will have:

• NINE calendar months to update their electronic EFT and/or ERA enrollment systems or forms and
• TWELVE calendar months to update their paper-based EFT and/or ERA enrollment forms.

The compliance timeframe for HIPAA-covered entities to adjust their systems and/or forms begins on the date of publication of the updated versions of the CORE-required Maximum EFT & ERA Enrollment Data Sets.

The CORE-required Maximum ERA Enrollment Data Set includes eight Data Element Groups (DEGs). For each DEG, Table 4.2-1, CORE-required Maximum ERA Enrollment Data Set, specifies whether the DEG is “required” or “optional” for data collection. Additionally, within each DEG, Individual Data Elements or Sub-elements may be designated as “required” or “optional” for data collection. This designation is provided in the “Data Element Requirement for Health Plan Collection” column in Table 4.2-1.

The “required” or “optional” designation identified in Table 4.2-1 is specific to whether a health plan, or its agent, must include the DEG or Individual Date Element/Sub-element on its ERA enrollment form/method. The CAQH CORE Payment & Remittance ERA Enrollment Data Rule does not address requirements for provider completion of the elements included on the ERA enrollment form/method. As such, if a health plan chooses to include an “optional” Individual Data Element or Sub-element on its ERA enrollment method, it is permitted by the CAQH CORE Payment & Remittance ERA Enrollment Data Rule vPR1.0 to make completion of this “optional” data element mandatory for enrolling providers.