Medicare Mandatory Reporting for HRAs: Increased Threshold Levels and Exhausted Account Balances
As a means of enforcing the Medicare Secondary Payer (MSP) Rules, the Centers for Medicare and Medicaid Services (CMS) impose a reporting requirement upon insurers, third party administrators, and plan administrators of self-funded, self-administered group health plans. CMS considers health reimbursement arrangements (HRAs) to be a group health plan for purposes of the MSP rules; and thus, subject to the Medicare Mandatory Reporting Requirement (see prior Benefit Beat articles, Mandatory Medicare Reporting for HRAs Clarified, Aug, 2010, and Updated Information: Mandatory Medicare Reporting for HRAs, June, 2010).
On September 27, 2011, CMS issued some clarifying guidance relating to the HRA reporting requirement:
- Increased Threshold Levels. HRAs have been subject to the reporting requirement if the HRA exceeds $1,000. According to the recent guidance, this threshold is increased to $5,000, effective October 3, 2011, applicable to the HRA’s next reporting year. This increased threshold should come as good news for certain stand-alone HRAs in that it may relieve them of certain reporting obligations.
- Exhausted Account Balances. This guidance provides that if an HRA is subject to the Medicare Mandatory Reporting Requirement, and if an individual has exhausted his/her benefit coverage under the HRA for the remainder of the coverage term, a termination notice must be filed with a Coordination of Benefits Contractor (COBC) in the next regularly scheduled MSP Input File Submission. In the alternative, this notice may be provided by contacting the COBC call center (1-800-999-1118). Once the individual account has been replenished in an amount exceeding $5,000, the reporting entity must then submit a new record reflecting the start date of the new coverage period. This provision became effective September 27, 2011.
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