Delayed Medicare Reporting Requirements Offers Reprieve To Companies

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Allsup outlines strategy to meet Medicare Secondary Payer (MSP) compliance, avoid costly fines

The temporary reprieve may serve as a boon to companies who still don't have a handle on what's required

Thousands of companies can benefit from the good news that they have an additional nine months to get on board with reporting requirements associated with Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSEA). The delay provides additional time for testing and preparation, according to Allsup, following the Centers for Medicare & Medicaid Services (CMS) decision to delay the start date for mandatory reporting requirements from April 1, 2010, to Jan. 1, 2011.

“The temporary reprieve may serve as a boon to companies who still don’t have a handle on what’s required,” said Rob Sokol, director of commercial sales-Medicare Secondary Payer (MSP) compliance at Allsup, which works with employers to coordinate their group health, disability and workers’ compensation benefit plans with Social Security and Medicare. “Businesses should use this time to ensure that when reporting requirements do take effect, they’ll be ready to comply.”

Effective Jan. 1, 2011, all responsible reporting entities (RREs), without exception, must comply with MMSEA reporting requirements or face stiff penalties of $1,000 per day and other liabilities. “To minimize their risk, insurers should have already begun the setup and testing process to meet mandatory insurer reporting requirements,” Mr. Sokol said.

“This is no easy task. Non-group health plans (NGHPs) must ensure their ability to effectively conduct queries about the Medicare eligibility of all their claimants,” he said. “This includes the technological capabilities to satisfy rigorous data collection that CMS now requires.”

CMS first stipulated reporting requirements take place in mid-2009. Now beginning Jan. 1, 2011, liability insurers, self-insurers, no-fault insurers and workers’ compensation insurers must determine the Medicare beneficiary status on all claims and report those claims involving a Medicare beneficiary to the U.S. Secretary of Health and Human Services.

MMSEA reporting requirements are designed to protect Medicare as the secondary payer through detailed reporting and severe penalties for noncompliance.

To avoid penalties and other liability, according to Mr. Sokol, NGHPs must take the following steps to ensure compliance:

  •     Complete RRE registration. RREs must register electronically with Medicare’s Coordination of Benefits Secure Web site (COBSW) to create the required secure interface for forwarding data.
  •     Establish/initiate claim procedures to determine the Medicare status of claimants.
  •     Complete a first round of data exchange, or test submission, to confirm that RREs, either directly or through a designated agent, are able to provide files including all the required information in the appropriate format and according to the CMS-define schedule.
  •     Begin quarterly claim file testing now.

“Without quarterly reporting, insurers can incur substantial penalties quickly,” Mr. Sokol said. “Providers can count on Allsup to provide expertise, assist with compliance and meet their obligations under Medicare regulations.”

Allsup can help RREs fully determine the Medicare beneficiary status to ensure MSP compliance. While CMS has provided a simple “yes” and “no” query capability as part of mandatory insurer reporting (MIR), Allsup’s Medicare Verification Services offer a more complete analysis of an individual’s Medicare beneficiary status in order to ensure compliance with all facets of MSP requirements.

Allsup’s Medicare Verification Services are the perfect complement to CMS’ MIR query process. For more information, contact Allsup at (866) 477-7005 or WCServices(at)allsupinc(dot)com.

Allsup is a nationwide provider of Social Security disability, Medicare and Medicare Secondary Payer compliance services for individuals, employers and insurance carriers. Founded in 1984, Allsup employs more than 600 professionals who deliver specialized services supporting people with disabilities and seniors so they may lead lives that are financially secure and as healthy as possible. The company is based in Belleville, Ill., near St. Louis.

The company has helped hundreds of self-insured employers, state and municipal governments, disability and workers’ compensation plans with Social Security and Medicare. This includes Medicare Set-Aside services to protect Medicare’s interests in workers’ compensation and third-party liability settlements; overpayment reimbursement services for participants with disabilities; and reverse offset services to identify workers’ compensation claims in states with SSDI-offset potential. For more information, visit

    Rebecca Ray
    (800) 854-1418, ext. 5065
    Dan Allsup, ext. 5760

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Rebecca Ray
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