Section title: Requests for Interpretation
RFI #
1940
Policy Term Dates in 820
Description

Referencing the Mortgagee Billing, Notification, and Payment ASC X12N 811/820 (004010X146 and 004010X308) guide and segments DTM*007 and DTM*036. In the current invoice billing process (811), part of the required information on the payment advice (820) is policy number, due amount, term dates, etc.. On the 820, our expectation is this same information would be returned on the 820 as billed. However, there is no NOTE or COMMENT in the 820 that states specifically that the term dates must match what was sent on the 811. Do you agree that the term dates on the payment advice file (820) must match the term dates from the 811? If so, would it be appropriate to add a COMMENT or NOTE to existing and future guides to include this as a requirement?

RFI Response

The X12 Standards and above-referenced Implementation Guides are silent on this question. These two transactions are grouped together as a guideline for the business usage of Mortgagee Notification and Billing (811) and Mortgagee Payment Information (820), as described in Section 1, Purpose and Business Overview, and Section 2, Data Overview. Section 1.3 states that the "811 is used by insurance companies as the method of billing and coverage notification to the mortgage company…" and "the 820 is used by mortgage companies for the payment information of those premiums that were held in escrow."

The business scenario is that insurance companies have the need to convey a vast amount of policy information to mortgagees for both billing the mortgagee and notification only purposes. Some examples of billing scenarios are a regularly scheduled consolidated billing covering a specific time period, or a daily transaction file for endorsement or cancellation bills. Notification examples include policy declarations, coverage summaries, reinstatements, and copies of premium notices when the insured pays the premium. The mortgagee in turn remits payment for policies when they have an escrow account established and insurance premium held on behalf of the insured. The guide also allows the mortgagee to remit payment for policies that were never included in any 811. With this business scenario, there is no expectation that every policy in an 811 will receive an 820 response, therefore no expectation that a payment must match a bill. With that general understanding , then there is no expectation that any of the data should match.
In the Remittance Advice Loop of Transaction 820, the DTM*007 and DTM*036 are both required segments, however the origin of these dates is not specified. Also within the RMR Loop is a Situational REF segment, REF*ABC, Policy Link Number. This same REF is available to the insurer in the 811 and is called Internal Policy Number. The intention is that if the REF*ABC is sent in the 811, it should be returned in the 820 for the insurer's internal use. This situational note is not specified in the 820, however it is noted in the 811.

RFI Recommendation

If there is a specific need for the insurer to match a policy in an 820 to a policy in an 811, the use of the REF*ABC would be one method to accomplish that.  Any other requirements would need to be agreed upon between trading partners.

A future version of the TR3 for 811/820 Mortgagee Billing, Notification, and Payment is currently being developed. The Work Group will specify Implementation Notes for segments used in the 820 to better describe the intended usage and requirements.

DOCUMENT ID
004010X146
004010X308