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June 7, 2010

Updated Information: Mandatory Medicare Reporting for HRAs

In an effort to ensure that the Medicare Secondary Payor rules are properly administered, the Centers for Medicare and Medicaid Services (CMS) imposed a mandatory reporting requirement on insurers, third party administrators, and plan administrators of self-funded, self-administered health plans, collectively referred to as “Responsible Reporting Entities” (RREs).  The type of information to be reported relates to Medicare beneficiaries who have group health plan coverage.   While this reporting rule became effective January 1, 2009, it is only recently become effective for health reimbursement arrangements (HRAs)(see CMS Clarifies Medicare Mandatory Reporting Requirement for HRAsBenefit Beat, August 2009).  CMS recently issued an Alert updating information relating to the mandatory Medicare reporting for HRAs.  Registration for HRA-only RREs began May 1, 2010 and must be completed by June 30, 2010.  The data submission testing period for HRAs will begin July 1, 2010; production reporting of HRA coverage information will begin October 1, 2010.


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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