Healthcare EFT Standard Frequently Asked Questions

General Information

  1. What is the difference between the IFC for the healthcare EFT standard and the IFC for the EFT & ERA Operating Rules?
    1. The Healthcare EFT Standard and Remittance rule identifies a HIPAA EFT standard format to be used for the claims reimbursement payment (ACH CCD+Addenda) and establishes a standard for the remittance information (the TRN Reassocation Trace Number) that must be included in the CCD+Addenda.  All health plans do need to offer out the CCD+ to their providers.
    2. The IFC for the EFT & ERA Operating Rules cover the usage of ERA & EFT in order to improve the efficiency and adoption of electronic transmission of payment and remittance advice.
  2. With these new Federal regulations, is the ACH Network carrying both the ERA and EFT transactions?
    1. No. The Federal regulations do not require that the ERA flow over the ACH Network; but the IFC does not prohibit the use of the CTX for the delivery of EFT and ERA.
  3. Where in the HIPAA regulations does it state that the health plans must deliver the healthcare EFT standard if it is requested by the provider?
    1. The healthcare EFT standard is now a HIPAA standard transaction and is therefore covered by the original HIPAA regulation 45 CFR 162.925

      45 CFR § 162.925 Additional requirements for health plans.

      (a) General rules. (1) If an entity requests a health plan to conduct a transaction as a standard transaction, the health plan must do so.
      (2) A health plan may not delay or reject a transaction, or attempt to adversely affect the other entity or the transaction, because the transaction is a standard transaction.

  4. Does the Healthcare EFT Standard rule allow for other forms of EFT transactions in addition to the CCD+Addenda through the ACH Network?
    1. Yes, the Healthcare EFT Standard rule established the NACHA CCD+Addenda as the healthcare EFT standard, but the rule does not prohibit the use of other EFT payment options including card and wire transfer.  However,  if a provider requests claims reimbursement payments using the healthcare EFT standard the health plan must deliver the payment using the CCD+Addenda format.
  5. Does the ACA mandate that Medicaid payments be made electronically by January 1, 2014 also apply to Medicaid claims reimbursements?
    1. No, Section 1104(d) of the Affordable Care Act applies only to Medicare Part A and B payments.   The amendment is a bit of an oddity in that it affects   Section 1862(a) of the Social Security Act that applies to Medicare, as opposed to most of the rest of Section 1104 that applies to HIPAA.


  1. Do all providers have to be on EFT by January 1, 2014?
    1. There is no requirement in the ACA that provider have to accept EFT from health plans. But if they request the Healthcare EFT standard for claims reimbursement the health plan must be able to deliver the payment as requested, similar to the other HIPAA standards (45 CFR 162.925).
  2. My organization is a provider. What do we have to give to our bank in order for the bank to automatically send us the data we need to re-associate the EFT payment with the 835 transaction?
    1. All financial institutions are required under the NACHA Operating Rules to deliver the remittance data IF it is requested.  The EFT & ERA operating rules require that providers contact their financial institution and discuss how they want to receive the remittance data, when it is to be delivered and potential costs associated with the remittance delivery.
  3. In Section 4.1 of the CORE EFT & ERA Operating Rules a provider must proactively contact their financial institution and request delivery of the CORE-required Minimum CCD+ Reassociation Data Elements requirement for reassociation.  Who should the provider talk to at the bank and what should they request?
    1. A provider should contact their financial institution and request the delivery of the ACH Payment Related Information.  If a provider is working with a cash management or treasury management officer they can request the delivery of the ACH Payment Related Information from them or talk to the customer service staff at the branch.
  4. Would the bank provide the ACH Payment Related Information (CCD+Addenda) data in paper or electronic form to a provider?
    1. Changes to the NACHA Operating Rules effective September 20, 2013 require that all financial institutions have the ability to deliver the ACH Payment Related Information to the provider through a secure electronic delivery option.  Financial institutions may have other options available via email, fax, or mail but all financial institutions must have one secure electronic option available.  Providers should discuss delivery methods, timing and potential fees for delivery of the information with their financial institutions.

Health Plan

  1. My organization is a payer, and if we do not currently offer EFT, must we implement that capability?
    1. Yes. The ACA requires all payers to certify compliance with the Healthcare EFT Standard and EFT & ERA Operating Rules by January 1, 2014.
  2. Is the Health Plan’s enrollment application/process or claims payment application/process required to generate the NACHA ACH CCD formatted file for prenotification for the Health Plan ODFI to send to the Providers RDFI?
    1. No, use of the prenotification under the NACHA Operating Rules is option and the use of prenotifications is not addressed in the CORE EFT & ERA Operating Rules.
  3. One of my financial institutions is asking us to make some changes for the upcoming CDD+ transaction rollout because of changes to the NACHA Operating Rules to support healthcare claims remittance payments.  Do you know where I could get a copy of some sample ACH files with the new TRN data for testing?
    1. The NACHA Healthcare EFT Standard Implementation Guide contains the CCD+Addenda file layout plus samples on how to populate the specific fields.  This publication can be purchased from NACHA online at .  NACHA does not have ACH test files; those may be obtained from your financial institution.

NACHA Operating Rules/CCD+Addenda Format

  1. Which types of organizations follow the NACHA Operating Rules? All healthcare entities?
    1. All participants in the ACH Network are bound to the NACHA Operating Rules through contracts; this includes the Originator (Health Plan), their financial institution (ODFI), the Receiver and their financial institution (RDFI), and any third-party vendors that may provide ACH files to the ODFI on behalf of the Originator.
  2. Will all RDIFs be able to report the reassociation number to the provider?  How?
    1. Under the NACHA Operating Rules all financial institutions must provide the reassociation (remittance information) to the provider IF it is requested.  Per the CORE reassociation operating rule, providers are required to request delivery of the reassociation number from the RDFI.
    2. The method of deliver will vary depending on the capability of the financial institution and the provider.
  3. What does the acronym CCD stand for?
    1. CCD stands for Corporate Credit or Debit entry. 
  4. Which field of the ACH CCD record needs to have HCCLAIMPMT supplied as identifiers?  Which field and record type?
    1. HCCLAIMPMT must be included in the Company Entry Description field. 
    2. Company Entry Description is in the Batch Header Record, Record Type 5, Field 7.
  5. How is the CCD+ format different from the 835?
    1. The CCD is a NACHA payment format to move money with limited remittance.  The 835 is an X12 EDI transaction set that can be used to request an ACH CCD be originated but is not a payment format for the ACH Network.

More FAQs

Looking for answers to questions related to The Affordable Care Act and Healthcare EFT Standards? Check out the Center for Medicare and Medicaid Resources (CMS) FAQs.