What should be sent in the TRN03/04 when sending an 835 for a self-funded group and the third party agent for the group is a traditional ‘payer’. We are a traditional ‘payer’ who are acting as the TPA for self-funded groups. We have interpreted the TRN03 element note to be that the self-funded group's Tax ID should be in the TRN03 since they are the payer. We have a provider who is requesting that our Tax ID be sent in order for them to be able to automatically post, because they do not ‘know’ the Tax ID of the self-funded groups, but they ‘know’ the Tax ID of TPAs and traditional ‘payers’.
Looking in the front matter (1.4 & 1.5) the definition of 'payer' appears to allow either the Tax ID of the self-funded group or their TPA.
Is there a way for the Tax ID of the self-funded group and the TPA to both be sent?
We were thinking of continuing to send the self-funded group’s Tax ID in the TRN03 while sending our Tax ID in the TRN04 so that both Tax IDs are sent. Would this be compliant with the TR3?
The TRN03 must identify the company initiating the funds transfer. The TRN03 element note reads: “A unique identifier designating the company initiating the funds transfer instructions, business transaction or assigning tracking reference identification.”
The TRN04 is “Required when information beyond the Originating Company Identifier in TRN03 is necessary for the payee to identify the source of the payment. If not required by this implementation guide, do not send.”
The TRN04 element note also reads: “If both TRN04 and BPR11 are used, they must be identical, excluding trailing spaces. Since BPR11 has a min/max value of 9/9, whenever both are used, this element is restricted to a maximum size of 9.”
Therefore, reporting the identifier of the company initiating the funds transfer instructions in the TRN03, and reporting an identifier beyond the Originating Company necessary for the payee to identify the source of the payment in the TRN04 is compliant with the TR3. When the TPA is the payer there is no need for an additional identifier in TRN04, since the payee knows who the payer is and doesn't know or need to know the self-funded group. When the self-funded group is the payer, including the TPA ID in TRN04 is appropriate since that is necessary for the payee to identify the source of the payment."