Good news: CMS allows reporting without the need to submit electronic files
In an alert posted to the Centers for Medicare & Medicaid Services (CMS) website, the government announced a new Direct Data Entry option for Liability Insurers, Self Insureds, No-Fault and Workers’ Compensation carriers. This should be welcome news to those companies struggling to meet data feed requirements mandated by the Medicare Secondary Payer Mandatory Reporting Provisions in Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007.
With this new option, a carrier or self-insured need not develop, test and manage claim reports through a data feed. While not without its limitations, the ability to enter single reports will be an applauded method for those entities with minimal reporting.
As I previously wrote about in Important Update: Medicare Secondary Payer changes production date to January 1, 2011, CMS changed the production date for reporting to January 1, 2011. Given the complex nature of the new reporting guidelines there has also been a recent bill submitted in congress to amend the statute (see Medicare Secondary Payer Enhancement Act). It seems clear that as the new reporting requirements have been put to the test, the government is making an effort to improve the process.
Who can use the Direct Data Entry
Those Responsible Reporting Entities (RRE) that are considered “Small Reporters” may utilize the Direct Data Entry method for compliance with the Section 111 requirements. The CMS Alert defines a Small Reporter as one who would submit 500 or fewer Non Group Health Plan (NGHP) claim reports per year. It is important to note that claim reports resulting in a “no beneficiary” match will still count against the 500 claim limit.
Direct Data Entry Option Considerations
- Those Small Reporters wishing to use this method for reporting will be able to register for the new option beginning on October 1, 2010
- Reports can begin to be filled using the Direct Data Entry method beginning January 3, 2011
- Injured party information will be matched in real-time as entered. Once the basic injured party information is entered if a match is not found then no further data elements will be required (this will however still count toward the 500 limit)
- There are no changes to the number of data elements required to be reported
- All RRE responsibility and accountability to report remains the same when using the Direct Data Entry option
Eliminating the need to create and submit electronic reports should alleviate issues for the Small Reporters and make compliance easier.
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Some background on the Medicare Secondary Payer Act and New Reporting Requirements
The Medicare Secondary Payer Act has been in place since the early 1980’s. The act allowed Medicare to seek reimbursement for money an insurance company or self insured pays on behalf of a Medicare beneficiary. MSP covers all carriers, self-insureds, no fault insurance, and workers’ compensation insurance. In the past, Medicare’s ability to track and enforce these claims was limited. With the passage of the SCHIP Extension Act of 2007, Medicare was given new tools to track payments. The passage alone marked the start of new steps to increase enforcement by the Federal Government to collect on the Secondary Payer provisions.
As part of the Act, the Responsible Reporting Entity (carrier or self-insured) must advise Medicare when a claim is received involving a Medicare beneficiary recipient. Responsible Reporting Entities now have an ongoing requirement to determine from time to time whether a claimant is a Medicare eligible recipient.
For more extensive information about the Medicare Secondary Payer Act and the new reporting requirements, please look to these valuable links:
