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September 4, 2008

New CMS Website for Medicare Payer Reporting

As described in the January, 2008 Benefit Beat, a new reporting requirement will be imposed upon insurers, third party administrators (TPAs), and plan administrators of self-funded, self-administered health plans.  The reporting requirement relates to the Medicare Secondary Payer (MSP) rules.  These rules require that a group health plan pay primary to Medicare in three instances: 

  • For employers employing 20 or more full or part-time employees, the group health plan pays primary for employees, or the dependents of employees, who are entitled to Medicare due to age. 
  • For employers employing 100 or more full or part-time employees, the group health plan pays primary for employees or dependents entitled to Medicare due to disability, as long as the employee has current employment status. 
  • For employers of any size, the group health plan pays primary for the first 30 months of the coordination period when an individual, employee or dependent, is entitled to Medicare due to end stage renal disease. 

Special rules apply to multi-employer plans with regard to the coordination through the MSP rules as they relate to age and disability.   

In an effort to ensure that the MSP rules are properly administered, a new reporting requirement will be imposed on insurers, TPAs, and plan administrators, effective January 1, 2009.  The specific rules relating to this reporting requirement have not been established; though, CMS has set up a website (http://www.cms.hhs.gov/MandatoryInsRep/) that will be used as the vehicle for this reporting.  It is expected that all the reporting will be electronic, and that reporting will be required no more frequently than quarterly. 

Generally, employers will not be involved in this reporting requirement, except to the extent that the insurer or TPA may ask the employer to assist in collection of the required information.

 

The information contained in this Benefit Beat is not intended to be legal, accounting, or other professional advice, nor are these comments directed to specific situations.

As required by U.S. Treasury rules, we inform you that, unless expressly stated otherwise, any U.S. federal tax advice contained in this Benefit Beat is not intended or written to be used, and cannot be used, by any person for the purpose of avoiding any penalties that may be imposed by the Internal Revenue Service.

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