CMS Guidance on VCCs, EFT/ERA, and Business Associates – What You Need to Know

In March 2022, the Centers for Medicare & Medicaid Services (CMS) released guidance on virtual credit cards (VCCs) and electronic funds transfer/electronic remittance advice (EFT/ERA) payment transactions, as well as business associate compliance with the Health Insurance Portability and Accountability Act (HIPAA) Administrative Simplification requirements. The enforcement policies outlined in these guidance documents are generally positive for physicians and are well-aligned with AMA’s advocacy on physician payment via VCC and EFT/ERA. This document offers an overview of CMS’s position on key issues as relayed by the agency’s guidance documents and provides recommendations for physicians navigating these policies.