What a clearinghouse outage does to cash flow, and the contingency plan to write before the next one

What happened in 2024, and why does it still matter?

A cyberattack on Change Healthcare in late February 2024 cut the link between a large share of providers and their payers, and on March 9, 2024 CMS made Change Healthcare/Optum Payment Disruption (CHOPD) accelerated payments available to Part A providers and advance payments to Part B suppliers¹. The amounts represented up to thirty days of claims payments, calculated as the total claims paid to the provider or supplier between August 1 and October 31, 2023, divided by three¹.

The terms are the part to remember. Repayment began immediately through 100% recoupment of Medicare claims payments for 90 days, with a demand for any balance left on day 91; providers had to certify that they couldn’t submit claims to Medicare and couldn’t obtain sufficient funding from other sources; and CMS said it could terminate the program at any time¹. That’s a short bridge loan, not relief, and it covered Medicare only.

So the lesson isn’t “CMS will step in”. It’s that one vendor sat between most practices and every payer, and when it failed, the practices that kept getting paid were the ones with a second route already enrolled. The clearinghouse entry explains what that vendor does; this post is about living without it.

Which payers can you reach without your clearinghouse?

Any payer with direct electronic submission or a provider portal, which for most practices means Medicare, the state Medicaid program and the largest commercial plans. Medicare’s EDI chapter requires its contractors to transact the 837 claim, the 835 remittance advice, the 276/277 claim status transactions and the 270/271 eligibility transactions with trading partners, and its enrollment section covers trading partner agreements, submitter numbers and the separate ERA enrollment form².

Build the map now. For each payer in your top ten by dollars, record whether it accepts direct EDI, whether its portal takes keyed claims, your enrollment status for each, who holds the login, and how it delivers remittances. The payers you can’t reach directly are the ones a backup clearinghouse has to cover.

What does a backup clearinghouse enrollment involve?

Payer-by-payer enrollment, which is why it takes weeks and why it has to happen before the outage. Opening the clearinghouse account is quick. The payer enrollments behind it aren’t: EDI agreements with each payer, ERA enrollment where the clearinghouse receives your remittances, and EFT changes if the vendor touches your banking. Medicare keeps electronic claims enrollment and ERA enrollment as separate steps², and most commercial payers mirror that.

Here’s the trade-off. A second clearinghouse costs money every month for a route you may never use, and two sets of payer enrollments are real work to keep current. The alternative is to enroll directly with your top five payers and accept that the long tail goes on paper or waits. Picking neither is the mistake. Whichever you pick, test it twice a year with a handful of live claims. The claim submission service page describes the acknowledgement routine a dedicated biller runs daily; in an outage it moves to the backup route unchanged.

How do you keep remittances and EFTs flowing when the 835 stops?

Keep remittances and EFTs flowing when the 835 stops by separating the money from the message: the EFT deposit is a bank transaction between the payer and your bank, the 835 that explains it is a data file that usually travels through the clearinghouse, and because the two fail independently, you check both on day one.

If deposits continue and files don’t, posting goes manual. Pull remittance detail from each payer’s portal, post it against the claims, and mark every payment posted this way so that when the 835 files arrive later they’re matched to existing postings rather than posted twice. Keep a running list of deposits with no remittance detail yet, by payer and date, so the bank reconciliation stays honest. The electronic remittance advice entry and how to read an ERA cover what the file normally gives you; the payment posting service page describes the daily routine.

How many days of cash do you need, and how do you calculate it?

Enough to cover operating costs from the day claims stop until the first payment arrives through your backup route, and only you and your accountant can set the figure. Monthly operating costs divided by 30 gives daily cost. Cash on hand divided by daily cost gives days of cash. Then estimate time to first payment on the backup route, including enrollment lead time if it isn’t done.

CMS sized its own bridge at 30 days of claims¹. Treat that as a reference for how CMS thought about the gap, not as a benchmark.

What does the week-one playbook look like?

Confirm the outage, switch eligibility to payer portals, freeze the unsent queue and sort it by filing deadline, then push the oldest claims through whatever route works. The sort key is “days left”, because a vendor outage doesn’t stop the clock. Medicare treats a submission as filed on the date the contractor receives it, denies claims whose receipt date exceeds 12 months or one calendar year from the date of service, says that denial isn’t an initial determination and can’t be appealed, and allows only four exceptions: administrative error on Medicare’s side, retroactive Medicare entitlement, retroactive entitlement involving a state Medicaid agency, and retroactive disenrollment from a Medicare Advantage plan or PACE organization³. A clearinghouse failure isn’t on the list. Texas Medicaid wants claims within 95 days of the date of service and accepts specific records as proof, including an electronic rejection report and an electronic claims report with the batch ID⁴.

Medicare uses the 999 to report syntax errors and acknowledge receipt of claims that had none, and the 277CA to report the claim control number of each accepted claim; a contractor may purge 999 transactions from the submitter’s mailbox after five business days if they haven’t been downloaded². Mid-crisis, those files are your only evidence of the receipt date, so download them daily. A rejection at the new front end never reached the payer, and proof of timely filing explains why that matters.

What to do this week

• Write the payer map: top ten payers, direct EDI, portal, enrollment status, login owner, ERA delivery path.
• Decide between a backup clearinghouse and direct enrollment with your top five payers, and start the enrollments.
• Calculate days of cash and write the number where the owner sees it.
• Save every 999 and 277CA by batch from today, so an outage never costs you the receipt date.
• Put the week-one playbook on one page and name who does each line.