The Financial Crimes Enforcement Network (FinCEN) recently published a set of frequently asked questions regarding the use of its new online Suspicious Activity Reports and Currency Transaction Reports. Credit union employees responsible for filing these reports are encouraged to review the FAQs for additional guidance on the new forms. Access the FAQs using these links: SARs CTRs on the FinCEN website.
The Healthcare Payments amendment to the NACHA Rules will take effect in September 2013. The new rule includes processing enhancements and transaction identification and formatting requirements specific to healthcare claim payments. For most credit unions, the impact of these changes should be limited to your business members who receive payments as a healthcare provider. However, credit unions should review their current ACH posting software and statement content to determine if any changes are needed before the amendment takes effect later this year.
Standard Entry Class (SEC) Code
The new entries will carry the CCD Standard Entry Class code as a business-to-business entry. Be aware that your consumer members may also be using their personal account for business purposes, and may therefore receive these entries as well if they are self-employed as a healthcare provider.
The Company Entry Description field will always contain the value “HCCLAIMPMT”.
Each entry will also include an addenda record that includes a TRN (Reassociation Trace Number) needed by your member to match the entry to the related electronic remittance advice sent separately by the Originator to your member. The TRN data will be listed as a combination of numbers, letters, and symbols. Here is an example of how the data may appear in the addenda record: TRN*1*12345*1512345678*999999999~
The new rules require that the credit union provide this addenda information to the member either automatically or upon their specific request. You will need to ensure that your ACH posting software includes this addenda information with each transaction so members can view the data via your home banking or other secure online system.
Complete details on the new ACH healthcare payments can be found at: http://healthcare.nacha.org. If you have questions about the Healthcare Payments rule change, contact SunCorp’s Member Services Department at 1-877-786-2677, option 1.