CMS to Physicians: You Don’t Have to Accept Virtual Credit Cards as Payment

Last Updated: Oct 12, 2017

The Centers for Medicare and Medicaid Services (CMS) has issued a series of FAQs addressing Electronic Fund Transfers (EFT) and virtual credit card payments. The FAQs clarify the rights of health care providers when it comes to claims payment transactions by all health plans, including commercial plans.

Key issues addressed by CMS' FAQs include the following:

  • Health plans – including payment vendors contracted by a health plan to conduct payment activities on their behalf – cannot require a provider to accept virtual credit card payments (i.e., single-use numbers that must be entered into a credit card point of sale system to receive payment). Providers have the right to request that a health plan use the EFT transactions, and health plans are required to comply with such a request.
  • Fees that may apply to a HIPAA EFT transaction for a provider include a banking transaction fee which, in 2017, averages around $0.34 nationally. If providers contract with vendors for additional services such as customer service or 24-hour hotline numbers, they should be aware that the vendors may charge additional fees. However, providers are not required to contract for these additional vendor services.
  • Health plans (and their payment vendors) should not charge providers communications fees for the use of the HIPAA EFT transaction. Any fees charged to a provider for an EFT transaction are the banking transaction fees explained above, which should be applied only by the provider's financial institution.
  • Signing up for EFT with a health plan does not automatically allow the plan or its business associates to deduct money from a provider's account unless contractually authorized by the provider.
  • Providers who are concerned that a health plan or business associate has not met HIPAA regulations concerning payment transactions can submit an online complaint here.

Additional Resources

You can access CMS' FAQs on EFT transactions here. The American Medical Association also offers this clarification on electronic transactions.

Pennsylvania Medical Society (PAMED) members with questions on EFTs and virtual credit card payments can contact our Knowledge Center at 855-PAMED4U (855-726-3348) or

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