Health Systems International

HSI Medicare Secondary Payor Mandatory Reporting

On August 1, 2008, the Centers for Medicare and Medicaid Services (CMS) released a statement clarifying the Mandatory Insurer Reporting Requirements of Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA).  Section 111 amended the Medicare Secondary Payor Statute (MSP) to mandate data reporting by Group Health Plans (GHP) and Non-Group Health Plans (NGHP).  NGHP Plans include workers’ compensation, liability insurance (including self-insurance), and no-fault insurance (including auto insurance).  The Mandatory Insurer Reporting Requirements carry significant penalties for non-compliance, specifically a civil penalty of $1,000.00 per day per claim if applicable claimants are not reported in a “timely” manner.

Health Systems International is committed to protecting the interest of our clients.  As such, we have finalized the EDI necessary to submit data to CMS to comply with the SCHIP reporting requirements.  A timeline of events for NGHP reporting, including registration, testing and "live data" exchange is included below:

• 03/16/09 - 06/30/09   EDI Requirements Released by CMS and Systems Development Begins
• 05/01/09 - 09/30/09   Electronic Registration via the COBSW for all NGHP Plans
• 01/01/10 - 03/31/10   EDI Testing for all NGHP Plans
• 04/01/10 - 06/30/10   All Responsible Reporting Entities (RRE’s) Must be Submitting Data

Self-Insured employers, insurance carriers, and other entities meeting the definition of Responsible Reporting Entity (RRE) are required to submit, on a quarterly basis, information of work-related injury claims involving Medicare beneficiaries.  Only RRE’s are required to comply with the new repoting requirements, and CMS has issued some guidance on how to determine whether an entity is an RRE.

For additional information, including the CMS User Guide, Alerts, online registration with HSI, and the Newsletters posted by our Settlement Specialists, please see below.  You may also call (800) 683-1254 and ask to speak with one of our Settlement Specialists, or email us at