Medicare Secondary Payer Mandatory Reporting

CMS Section 111 Mandatory Reporting

Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSEA), added mandatory reporting requirements for certain insurers, self-insured entities, and third party administrators that will enable the Center for Medicare and Medicaid Services (CMS) to determine when the Medicare program does not have primary payment responsibility for expenses that are able to be reimbursed by Medicare. To comply with Section 111 reporting, HR Concepts has been tracking in greater detail the data necessary for these reporting requirements. The CMS Section 111 rules apply to different types of plans such as Healthcare Reimbursement Arrangements which would identify HR Concepts as a "Responsible Reporting Entity" or RRE.  Since HR Concepts is administering the HRA plan for a number of our clients we have been taking steps to ensure that we have the most current Medicare related information available to CMS.  Section 111 reporting is required for HRA plans that cover medical benefits though there are exceptions to this which include the following:

HRA plans that only cover dental or vision services. HRA plans where the employer funding is less than $1,000. HRA plans that are provided to a retiree or any individual where Medicare coverage is primary to the employer's health plan.
No reporting is required for Flexible Spending Accounts or Health Savings Accounts.

Any employer group who subscribes to an HRA plan with employer funding of at least $1,000 will need to be included with this reporting. This includes employees or dependents aged 45 and older who are enrolled in an HRA. It also includes covered individuals who have been receiving kidney dialysis or who have received a kidney transplant. In order for our systems to be able to identify potential Medicare claimants and to have the most accurate data, we may be requesting additional or updated information in the following areas:

Employee Information:

  • Age
  • Current Medicare beneficiary (yes/no)
  • Medicare ID (HICN)
  • Dependents
  • Current Medicare beneficiary (yes/no)
  • Age
  • SSN
  • Medicare ID (HICN)

Employer Information:

  • Employer size (total # of employees)
  • Plan sponsor name
  • TIN
  • Corporate Address

If HRC is currently administering your HRA plan and you are offering a minimum of $1000 in employer funding our client relations teams will be reaching out to you in the coming weeks to update these data elements.  The initial reporting period designated by CMS will be October 1, 2010 for HRAs with plan years beginning October 1. The first reporting period for HRA plans with a calendar year plan year will be January 1, 2011 to March 31, 2011. We hope you appreciate HR Concepts ongoing efforts towards maintaining our compliance with federal regulations and apologize for any inconvenience this process may incur on your behalf.


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