Brenda, the 834 issue was discussed in detail from the provider's point of view (as an employer) this week in the thread entitled "Covered Entity as an Employer," in the archives at http://www.mail-archive.com/wedi-transactions%40lists.wedi.org/. On Thursday, in the same thread, Kathleen Connor included a detailed exposition of the 834 and 820 requirements with respect to employer-sponsored ERISA health plans; this background is applicable to your situation.
Your analysis of the 834 and 820 usage seems reasonable (i.e., that the 834 would not be used for the census, nor would the 820 be used for employee deductions for health care costs). But the reasoning has nothing to do with the administrator not being a health plan. The Third Party Administrator (often an insurance company in its own right) is the business associate of your self-administered health plan, and must support the 820 and 834 when applicable; see Kathleen's variation (3). William J. Kammerer Novannet, LLC. Columbus, US-OH 43221-3859 +1 (614) 487-0320 ----- Original Message ----- From: <[EMAIL PROTECTED]> To: "WEDI SNIP Transactions Workgroup List" <[EMAIL PROTECTED]> Sent: Friday, 21 March, 2003 11:12 AM Subject: Group Health Plan - 820 and 834 transactions My legal department has determined that we are a 'group health plan' for both the medical and dental coverage we provide to our employees and therefore must abide by the regulations for the 834 and 820 transaction. Based on that, we have come to several conclusions that I would like to get confirmation on, and also have an outstanding question. 1. We have 2 types of Flexible Spending Accounts, a Personal Spending Account for Medical expenses and a Personal Spending Account for Dependent Care expenses. We utilize a vendor to administer the benefit and send them a census file in addition to a wire transfer for the employee deductions. For the 834 transaction, the regulation clearly states that it is for the subscriber enrollment information to a health plan to establish or terminate insurance coverage. We feel that the census file to the administrator doesn't meet the criteria since it is not for the enrollment or disenrollment into a health plan for insurance coverage, and because the administrator is not a health plan. For the 820 transaction, the regulation states that it is the transmission of certain data from the entity that is arranging for the provision of health care or is providing health care coverage payments for an individual to a health plan. We have determined that we don't need to use the standard since the funds are employee deductions for health care costs and not premium payments, and also because the administrator is not a health plan. 2. We utilize a software package provided by our bank to transfer funds from our bank account to a health plans account for premium payments. Does this transaction require the use of the standard 820 format or is the financial institution excluded from being compliant? Appreciate any input. Brenda Joubert Project Leader Harvard Vanguard Medical Associates [EMAIL PROTECTED] --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-transactions as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
