Virtual credit card payments from payers are claim payments sent as a single-use card number that the practice runs through its card terminal. The card network takes a processing fee, usually a percentage of the payment, so the practice deposits less than the plan paid. A practice can ask each payer to pay by ACH EFT instead.
How virtual credit card payments from payers arrive
Virtual credit card payments from payers arrive as a single-use card number, issued for one payment and one amount, with the details needed to run it. Someone at the practice keys those details into the card terminal to collect the money. A remittance explaining which claims the payment covers comes with it or separately.
CMS describes the practice plainly. The CMS guidance letter GL-2022-04 on virtual credit cards and the EFT and ERA standards (dated March 22, 2022) says some health plans pay claims by sending providers a single-use credit card number. It says providers must manually enter the number into their point-of-sale terminals to receive payment from the card networks.
Card notices can reach the office through any channel the payer or its payment vendor chooses. Check every inbound route your office uses, including fax, mail and payer portals, so a card notice does not sit unopened until it expires.
The remittance that comes with a card
The card number alone says nothing about which claims were paid. The explanation sits on a remittance: a paper explanation of benefits (EOB), a portal page, or an electronic remittance advice (ERA), the X12 835 file.
The 835 does not describe a card payment the way it describes others. The CMS FAQs on GL-2022-04 (dated July 14, 2022) say version 5010 of the 835 has payment method codes for payments through the ACH network, by check and by wire transfer, but not by virtual card. Check how each card-paying payer marks these remittances, so posters can recognize them.
Keep the card notice and the remittance together from the moment they arrive. A card run without its remittance becomes money with no claim attached, which is how many items end up on the list covered in the guide to handling unapplied payments in payment posting.
What do virtual credit card payments cost a practice?
Virtual credit card payments cost a practice the card processing fee on every payment, taken out of the amount the plan paid. GL-2022-04 says card networks typically charge providers a fee of a percentage of each payment. An ACH EFT for the same amount carries no card network fee, though your contract may set other payment terms.
The rates depend on your merchant agreement and the card type, so the example below uses three illustrative rates. They are not published figures. Swap in the rate from your own processor statement.
A worked example
The payment is a fictional $2,400.00 from Example Health Plan covering six claims.
| Payment method | Example fee rate | Fee | Amount the practice keeps |
|---|---|---|---|
| Virtual card | 2.5% | $60.00 | $2,340.00 |
| Virtual card | 3.0% | $72.00 | $2,328.00 |
| Virtual card | 3.5% | $84.00 | $2,316.00 |
| ACH EFT | No card fee | $0.00 | $2,400.00 |
The gap looks small on one payment. It grows with volume. If a practice took a fictional $10,000 a month in card payments at the 3.0% example rate, the fees would come to $300 a month, or $3,600 a year, on money the plan already agreed to pay.
There is a labour cost as well. Every card payment needs someone to key the number, check the amount, keep the authorization record and match the deposit. An ACH EFT with an ERA can be matched by trace number.
HHS does not set or cap these fees. GL-2022-04 says HHS has not issued HIPAA regulations governing claim payments made with virtual cards, so it does not regulate common business practices around them, including fees charged by health plans or card networks. Your payer contract is where fee terms live.
Posting a virtual credit card payment against its remittance
Posting a virtual credit card payment takes three entries: the full payment applied to the claims on the remittance, the card fee recorded as a practice expense, and the bank deposit matched to the net amount. The patient accounts show what the plan paid. The fee never touches a patient claim.
The order matters, and so does keeping the fee out of the claim. If a poster applies only the net amount to the claims, every claim looks underpaid, and someone later chases a shortfall the plan never caused.
Step by step
- Run the card for the exact amount on the notice. Keep the terminal receipt with its authorization number.
- Post the full payment to the claims. Use the remittance line by line, just as you would for a check: service lines, allowed amounts, plan payments and remark codes, the same EOB fields named in the document types section of the Schema Care homepage. For the fictional example, $2,400.00 goes across the six claims.
- Record the fee in its own expense account. At the 3.0% example rate, $72.00 goes to card processing fees, with a note naming the payer, the remittance date and the authorization number.
- Match the deposit. Depending on your processor, the bank shows either one net deposit of $2,328.00 or a gross deposit of $2,400.00 and a separate fee debit. Match whichever it is to the posted payment and the fee entry.
- File the card notice and receipt. Store them with the remittance, in the same place you keep other payment records.
Matching the deposit is ordinary reconciliation once the fee is accounted for. When the amounts still differ, the guide to reconciling EFT payments with EOBs when amounts differ walks through finding the gap.
Handling the card details
A card notice carries a working payment number alongside patient and claim details. Limit who can open it, do not copy the card number into notes or tickets, and destroy or archive it under your records policy once the payment is collected. The HIPAA and PHI category covers how practices handle documents that hold patient information.
Can a practice turn down virtual credit card payments from payers?
A practice can ask a payer to stop paying by virtual card and pay by ACH EFT instead. CMS guidance says a health plan must comply when a provider requests payment using the adopted EFT standards. The provider has to enroll for EFT and ERA with that payer first. This describes CMS guidance, not legal advice for your situation.
The CMS FAQs answer the question directly. They say that if a provider asks a health plan that pays by virtual card to pay through the ACH network using the adopted EFT standards, 45 CFR 162.925(a)(1) requires the plan to comply. The eCFR text of 45 CFR 162.925, the rule on conducting standard transactions (eCFR up to date as of October 14, 2026), says that if an entity asks a health plan to conduct a transaction as a standard transaction, the plan must do so.
The adopted EFT standard is specific. The eCFR text of 45 CFR 162.1602, the EFT and remittance advice standards, names the NACHA CCD+ Addenda format with the X12 835 TRN reassociation trace number segment for payment initiation, and the X12 835 version 005010X221 for the remittance. GL-2022-04 adds that the plan must comply whether or not the provider is in its network.
Two limits are worth knowing. The CMS FAQs say HIPAA does not require a plan to honour a request for paper checks; ACH EFT is the only payment method a plan must provide on request. And GL-2022-04 says a plan may not require a provider to accept payment or reassociation services from a vendor of the plan's choosing as a condition of receiving standard EFT and ERA.
On fees for EFT itself, the CMS FAQs say the guidance does not address whether charging fees for standard transactions is, in and of itself, a HIPAA violation. They add that conditioning standard EFT on accepting unwanted services may be treated as adversely affecting the transaction. If a provider believes a plan is not complying, the FAQs point to a complaint through the CMS Administrative Simplification Enforcement and Testing Tool (ASETT).
An opt-out request checklist
Send the request in writing, and keep a copy. Include:
- The practice's legal name, NPI and TIN, matching your enrollment records.
- A clear request that the plan pay all claims by ACH EFT using the adopted standards, and send remittances as X12 835 files.
- Your EFT and ERA enrollment status with that payer, or a request for the enrollment forms if you have not enrolled.
- The payment vendor's name, if card payments come from a vendor rather than the plan itself.
- A named contact at the practice and a date by which you expect a reply.
- A note in your payer file with the date sent, who sent it, and the confirmation when it arrives.
The enrollment itself is covered in the guide to ERA and EFT enrollment with payers, which lists the details payers ask for.
Virtual card opt-outs that quietly lapse
Virtual card opt-outs quietly lapse when a payer changes its payment vendor, renews a contract, or moves the practice to a new payee record. Card payments start arriving again, and nobody notices until the fees show up on a processor statement. Watch for the first card from any payer you already moved to EFT.
The lapse is easy to miss because the money still arrives. A poster keys the card, the claims post, and the fee goes to an expense account no one reviews weekly. Months later, someone asks why card fees went up.
How opt-outs get lost
- A new payment vendor. GL-2022-04 says health plans often use business associates and vendors to handle payments. When a plan switches vendors, the old vendor's record of your opt-out may not move with it.
- A contract renewal. New payment terms can come with a renewed contract. Read the payment section before signing.
- A new payee record. A change of address, TIN or group can create a fresh record at the payer, set to its default payment method.
The plan stays responsible when a vendor gets it wrong. GL-2022-04 says that if a plan directs providers to a business associate that cannot pay using the adopted EFT and ERA standards, the plan may be held accountable for that noncompliance.
Catching a lapse early
Set one check in the posting routine: any card payment from a payer marked "EFT" in your payer file goes to the billing supervisor before it is run. The supervisor confirms whether the opt-out still stands, resends the written request if it has lapsed, and logs the date.
Review card fees once a month too. Sort the processor statement by payer, and compare the list with the payers you expect to pay by card. Any surprise name is a lapsed opt-out or a new payer to enroll.