April 7, 2009

Medicare Mandatory Insurance Reporting

Medicare is requiring insurers, third party administrators, and self-administered, self-funded health plans, to report information about certain plan participants (see New CMS Website for Medicare Payer Reporting , Benefit Beat, September 2008, and New Medicare Reporting Obligations ,Benefit Beat, January 2008).

By April 30, 2009, responsible reporting entities (RREs) must have registered on-line with Centers for Medicare and Medicaid Services (CMS) and complete their account set-up.  The account set-up process is described in detail in Section (page 27) of CMS’ Group Health Plan User Guide.  According to the User Guide, the website for registering (www.Section111.cms.hhs.gov), is not yet available, but the requirements for registration can be reviewed in CMS’ Registration Overview .

Generally, stand alone dental and vision plans, stand alone behavioral health plans, flexible medical spending accounts, and health savings accounts are not subject to this reporting requirement. 

Health reimbursement accounts (HRA) are subject to the reporting requirement.  If the employer self-administers its HRA, it is considered to be the RRE.  However, the reporting requirement is delayed until the 4th quarter of 2010.  It appears, though, that HRAs must accomplish the registration and account set-up by April 30, 2009, even though the first report will not be due until the 4th quarter of 2010.  If the HRA is administered by a third party, then the third party will be the RRE.


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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