CMS Alerts on MSP Mandatory Reporting Requirements

CMS has issued a series of guidance documents on the Medicare Secondary Payer (MSP) mandatory reporting provisions in section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSEA). The new guidance documents address: risk management write-offs by providers, physicians, suppliers, and non-provider/supplier entities; reporting health reimbursement arrangements; what entities are MMSEA Section 111 Responsible Reporting Entities (RRE) for liability insurance (including self-insurance), no-fault insurance, and workers’ compensation; and the new direct data entry (DDE) option for reporting non-group health plan information under Section 111. 

CMS Extends Medicare Secondary Payer (MSP) Reporting Deadline to January 1, 2011

Medicare is the “secondary” payer of health benefits for Medicare beneficiaries when another entity is the “primary” payer. Under new MSP enforcement rules, all entities that are considered primary payers and meet the definition of a responsible reporting entity (RRE) must register with CMS and comply with certain reporting requirements. Such RREs include (1) group health plans, and (2) non-group health plan (NGHP) arrangements, such as carriers of liability insurance (including self-insurance), no-fault insurance, and workers’ compensation. CMS recently announced it is extending its reporting requirement for NGHPs until January 1, 2011. CMS also has posted three new alerts on NGHP RRE Compliance, NGHP Alert Risk Management and NGHP RREs Who Must Report.