Centers for Medicare and Medicaid Services Announces Details on Medicare Secondary Payer Reporting Requirements
Allsup explains latest development from the Centers for Medicare and Medicaid Services affecting group and non-group health plans
Belleville, Ill. – Sept. 3, 2008 – The Centers for Medicare and Medicaid Services (CMS) recently provided more details on Medicare secondary payer reporting requirements that are important for group and non-group health plan providers to evaluate, according to
Allsup. Based in Belleville, Ill., Allsup helps employers manage and protect health insurance, workers’ compensation and benefit costs for both employers and employees.
On Aug. 1, CMS released a Supporting Statement for the Medicare Secondary Payer (MSP) Mandatory Insurer Reporting Requirements (MIR) of Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSEA).
As Allsup previously reported, the MMSEA provides mandatory reporting requirements for group health plans and liability insurance (including self-insurance), no-fault insurance and workers’ compensation providers. The mandatory reporting requirements of Section 111 of the MMSEA carry significant penalties for non-compliance.
“It’s important for providers to consider the impact of reporting changes to their plan processes,” said Rob Sokol, director of commercial sales at
Allsup. “CMS estimates these changes may cost providers $12 million and more than 1 million man-hours.”
The Mandatory Insurer Reporting section of MMSEA imposes new claim reporting requirements on claims departments, Mr. Sokol explained. The financial penalty is $1,000 per claim per day for noncompliance.
“The law places the burden of identifying Medicare beneficiaries on these claims departments and to report this information in a timely manner,” Mr. Sokol said. In addition, MMSEA provides CMS with the opportunity to increase enforcement of the Medicare Secondary Payer laws beyond
workers’ compensation claims.
“Allsup can provide expertise to make this a less costly and burdensome process,” he said. “We also can provide the insights to help providers react well and handle the changes properly and efficiently.”
First Look at Reporting Requirements
The Aug. 1 CMS supporting statement provides a first look at the required reporting elements and the burden of reporting that the federal agency will require.
The first step for reporting entities will be to register with CMS via an online secure Web site, which is still under development at this time. CMS has stated the mandatory reporting will be a fully electronic process to reduce paper and facilitate compliance.
Specific to Certain Entities
According to the CMS supporting statement, liability insurance (including self-insurance), no-fault insurance and workers’ compensation providers will be required to report the following categories of information about claims*:
- Mandatory data, including name, address, birth date, type of insurance, policy and claim numbers.
- Situational data, such as Social Security number, date of death, no-fault policy limits and claimant information (if different from injured party).
- Optional data, including e-mail addresses, telephone numbers and other details.
The CMS reports that this type of information must be reported on an ongoing basis (quarterly or less frequent) for non-contested workers’ compensation claims. In addition, this information must be reported on a one-time basis for all contested cases worker’s compensation cases in which a settlement, judgment, award or other payment occurs.
Costly Changes
The federal agency also provided an estimate of the burden MIR will place on reporting entities in both hourly and dollar terms. CMS officials do not believe that the collection of the required data elements will cause an undue burden although there may be some effort involved to centralize such information for reporting purposes.
Much of the data required by the MIR already is maintained for coordination of benefit and internal business purposes, according to the CMS.
As a result of the reporting requirement, providers likely will expend costs toward:
- Establishing a routine reporting process.
- Collecting required information.
- Time to complete a report on each claim.
CMS anticipates that the initial cost of compliance for all non-GHP entities will exceed $12 million and total more than 1 million man-hours. The agency also reports an estimated 2.9 million non-GHP claims are made annually by Medicare beneficiaries that may or may not be settled.
Once the reporting changes are implemented, CMS anticipates an annual ongoing maintenance and support cost to the federal government for this activity will be $8 million per year.
Count On Compliance Help
The recent CMS supporting statement provides some additional insights, but it still leaves much to be learned, said Mr. Sokol.
“The industry has a better sense for what information is going to be required and the potential burden, but we anticipate additional announcements,” Mr. Sokol said. “Allsup will do its part to continue communicating and supporting providers with the details and knowledge that will get them into compliance with as few headaches as possible.”
Additional details are expected on the reporting method, how the civil penalties for non-compliance may be assessed and most importantly how to properly identify all the Medicare beneficiaries in the system, Mr. Sokol said.
“As new information becomes available on MIR, Allsup will keep you informed,” Mr. Sokol added.
ABOUT ALLSUP
Allsup Inc., Belleville, Ill., is the nation’s premier provider of Social Security and Medicare coordination services for employers, long-term disability (LTD) and workers’ compensation insurers and third-party administrators. Companies can significantly reduce disability, group health and workers’ compensation liabilities by properly coordinating benefits with Social Security and Medicare programs. Founded in 1984, Allsup offers a comprehensive solution to minimize exposure to the Medicare Secondary Payer laws and produce savings by properly coordinating workers’ compensation benefits with Social Security and Medicare.
For more information, visit
www.AllsupInc.com.