The Clock Is Ticking for Companies to Meet Mandatory MMSEA Reporting Requirements, Allsup Reports

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Registration by Sept. 30 is necessary to provide a full quarter of testing before Jan. 1, 2011

Allsup specialists can help you interpret Centers for Medicare & Medicaid Services’ guidelines and help you understand if your organization may be a responsible reporting entity.

Allsup reports that companies are taking advantage of the additional time, through September, to register and meet reporting requirements associated with Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSEA). Allsup works with employers to coordinate their group health, disability and workers’ compensation benefit plans with Social Security and Medicare.

Allsup provides compliance solutions that meet the complex requirements issued by the Centers for Medicare & Medicaid Services (CMS) and is monitoring the response to MMSEA closely. “Businesses are digging into the details of complying with the mandatory reporting requirements to ensure they have the ability to properly test their programs before the deadline for compliance,” said Rob Sokol, director of sales-Medicare Secondary Payer compliance at Allsup.

CMS has provided additional time to comply, but ideally organizations will register by Sept. 30, 2010, in order to complete a full quarter of testing prior to Jan. 1, 2011, Sokol said.

“When the requirement takes effect, 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,” Sokol said. “Allsup specialists can help you interpret CMS’ guidelines and help you understand if your organization may be an RRE.”

Reporting Requirements and Payments

The act requires group health plans, liability insurers, no-fault insurers and workers’ compensation insurers to report information to CMS about payments to Medicare beneficiaries. This information assists CMS in coordinating benefits paid to individuals for whom Medicare is the secondary payer, enabling CMS to stop making payments when another entity is required to pay, and to recover past payments the insurer should have paid as primary. The requirements under the act are referred to as mandatory insurer reporting (MIR) requirements.

“Being able to implement a thoughtful solution to meet the new requirements takes detailed knowledge of CMS’ complex rules regarding secondary payer reporting,” according to Sokol. “MIR compliance will involve both changes in claim triage processes, as well as data storage and reporting needed to demonstrate compliance. Meeting all of these needs can be tough for an organization to accomplish quickly in-house.”

Allsup professionals maintain continuous contact with CMS to adapt the company’s services to the evolving requirements of CMS, and they offer thorough review that ensures accurate reporting. Allsup’s comprehensive mandatory insurer reporting service incorporates a web-based application that provides continuous and proactive response, monitoring, quality control and immediate assistance to responsible reporting entities allowing easy compliance with mandatory provisions of MMSEA Section 111.

Allsup specialists also provide personalized, expert assistance to:

  •     Coordinate registration.
  •     Handle CMS submission testing.
  •     Manage monthly query function, data transfers, compliance review, response and reporting in a timely manner.
  •     Provide quarterly CMS records submission, review, reporting and assistance.
  •     Provide secure web portal access for updating records, checking status and reporting.
  •     Provide scheduling notification to claims examiners.
  •     Provide response-file analysis and reporting, as well as additional quality control measures.
  •     Handle data storage for 10 years.

In addition to mandatory reporting requirements when accepting ongoing medical responsibility for a claim, companies also need to fulfill MSP rules that apply in workers’ compensation cases when settling a claim. At settlement, CMS’ interests as secondary payer must be protected, meaning that the companies involved are required to set aside funds for future medical care and to reimburse Medicare for past payments, if necessary.

“This is an area where companies need a lot of help to comply, especially in the general liability claims practices,” Sokol said. “Allsup’s expertise helps ensure that no insurer has to go it alone in attempting to comply with complex and evolving rules. Our Medicare Set-Aside services help carriers to protect themselves by complying properly.”

New Developments Likely

Companies can expect additional new developments in this area of compliance, Sokol added. “The industry right now is struggling to define and apply the best formula for handling the tremendous costs and overpayments inherent with the system as it now exists,” he said. “As a result, insurers can expect ongoing adjustments to the CMS mandatory insurer reporting format and structure as well as increased scrutiny in the other areas of MSP compliance.”

Allsup experts are working with clients to complete data transfer between CMS and Allsup. “We are in various stages of testing with each of our MIR clients,” said Donna Van Dorn, project manager and technology specialist. “Allsup also closely monitors and adapts to the constantly evolving requirements for data format, a big plus for customers.”

“We keep a close watch, monitoring the federal agency’s alerts and updates, as well continuing participation in CMS’ meetings before the program takes effect,” she said.

For more information about Medicare Secondary Payer compliance and reporting requirements, contact Allsup at (866) 477-7005 or MSAservices(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 nearly 700 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.

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