BPR06-11 is required for ACH. We have a situation where we the payer produce the 835 ERA but a separate entity actually does the EFT. WE the payer are the administrator of a self-funded (ASO) account. We are the administrator of their benefit plan and send the 835 however they are responsible for the actual Payment of the claims (check and EFT). AS the sender of the 835 to the provider and we being a HIPAA covered entity are we required to report the EFT in the 835 as well as all of the respective BPR account information ( ie Sender's account info etc)?
As the agent of the ASO, and the sender of the 835, you are required to provide an 835 that is compliant with the TR3. The 835 must report valid payment information. If the payment is via electronic funds transfer (EFT) using the banking system automated clearinghouse (ACH), only that mechanism of payment reporting in the 835 is compliant. Therefore, you must report that the payment is by EFT using the value "ACH" in data element BPR04 and all of the other appropriate BPR segment information where the BPR data elements situational rule state: “Required when BPR04 is ACH, BOP or FWT. If not required by this implementation guide, do not send”. The requirements of the 005010X221A1 835 TR3 apply to any sender of the 835 regardless of whether they are a HIPAA Covered Entity or not.
The EFT information is also required to facilitate the re-association of the payment and the remittance. See sections 1.10.2.2 Remittance Tracking and 1.10.2.3 Re-association of Dollars and Data of the 005010X221A1 TR3.
See RFI# 2041 for additional information on TPA’s acting on behalf of self-funded groups.See RFI# 2041 for additional information on TPA’s acting on behalf of self-funded groups.