CMS has clarified, by way of theirUser Guide, that they consider health reimbursement arrangements (HRAs) to be a group health plan, for purposes of the Medicare Secondary Payor rules; and thus, subject to the Medicare Mandatory Reporting Requirement.  Responsible reporting entities (“RREs”) of HRAs do not need to register with CMS at this time. HRA data will not be collected for reporting until after October 1, 2010. HRA-only RREs must register with CMS by May 1, 2010 to allow enough time for testing to be completed before production files are due.

Background Benefit Beat articles regarding the Medicare payor reporting requirement:

• Medicare Mandatory Insurance Reporting (4/7/09)
• New CMS Website for Medicare Payer Reporting (9/4/08)
• New Medicare Reporting Obligations (1/10/08)

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