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Back  RFI # 1451: Restriction of PO Box use

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Submitter

Description

The new 5010 requirement, whereby the Billing Provider Address restricts the use of a PO Box, is creating a problem for the health care industry as we transition to 5010. Many providers are reluctant to change it from containing a PO Box, as they fear that the payments will not go to the correct place. Although the industry has done a lot of outreach through various venues, a high percentage of claims are still submitted with a PO Box in the Billing Provider Address. Many payers have indicated that the provider address information on the claim is not used. However, they are reluctant to relax the requirement as they are striving to be compliant. We are looking for clarification from X12 that will allow the payers to continue to receive the PO Box if they do not require a physical address in the Billing Provider Address to adjudicate their claims. Without this direction, we will continue to see work-arounds such as changing the PO to P0 in order to get by the payers’ front end translator edits.

Submitter Assigned Keywords

PO Box

Response

This issue is explicitly addressed in guide 005010X222A1. There is no direction available related to loosening the requirement that the Billing Provider address must not be a PO Box. Sending a PO Box in loop 2100AA is not compliant with the TR3 instructions. X12 does not govern the receiver's actions when receiving a transaction that is not compliant with the specified implementation guide. Section 2.2.1.1 makes this clear with the statement "The receiver will handle non-compliant transactions based on its business process and any applicable regulations." Questions related to any regulatory requirement to reject a HIPAA transaction must be directed to CMS.


Rationale for the change:

The change not to allow a PO Box, Lock Box or the like in the Billing Provider address was done because these are Pay-to Addresses and therefore belong in the Pay-to loop (2100AB).

Payers requested the change to help resolve NPI issues. The expectation was that one of the service locations associated with the billing provider NPI would help in identifying the proper provider group in the payer’s database since a physical address in most instances is the one on the providers record in the payers database. Receiving only the PO Box address for the provider made matching difficult, since the service facility address may not belong to the billing provider. In addition, payers typically make payment to the address supplied by the provider as the payment address during the enrollment and credentialing process and not the address supplied on the claim.

This change was made after consultation with and with agreement from both the NUCC and NUBC on the billing provider address requirements for claims.
Submission 11/16/2011
Status Date 12/16/2011
Status F - Final
Primary References
Document 005010X222
Section2.4
Page91
Loop2010AA
Segment IDN3
Secondary References
RFI ID 1904
Document 005010X223
Section2.4
Page87
Loop2010AA
Segment IDN3