3/31/2010
Medicare Mandatory Reporting Timelines Revised and Quick Reference Guide
March 29, 2010 CMS issued a Revised Quick Reference Guide for MMSEA Section 111 Registration (updated Oct. 7, 20131) For Responsible Reporting Entities. But note that CMS cautions everyone that you must read the full updated User Guide.
Q: Why does Medicare supply a 43 page "User Guide" to mandatory claim reporting?
Answer: because the full updated User Guide to Mandatory Reporting (Ver 4.0) updated (Oct. 7, 2013) takes up 463 pages broken down into .pdf sub-parts on the CMS website.
It is anticipated that yet even more changes will be forthcoming but for the most part, most of the gross outline of the claim reporting process, the required data elements and the main provisions have taken shape. There have been substantial changes in this updated User Guide edition in response to industry concerns most notably in regard to who is considered to be a reporting entity (RRE) and in dealing with companies that have a deductible in their workers comp policy.
More CMS Town Hall tele conferences are scheduled for later this year up through June 30,2010 to address even more questions and more industry concerns. Because this changing area of law and the actual requirements are still unfolding, either check with an experienced Illinois workers compensation attorney with questions on where to look for answers or hire a specialized consultant in Medicare Secondary Payor requirements that can closely monitor this specialized area for precise reporting compliance.
If you have reporting responsibilities at your company, you should continue to monitor the CMS page on MMSEA very closely for any new developments and monitor the CMS page for Liability Insurance and Workers' Compensation Reporting for the most up to date information.
Chicago Workers Comp Attorneys -- 3-31-10
2/19/2010
Mandatory Claim Reporting Date extended to Jan 1, 2011
2-19-10
CMS MIR update alert advises workers' comp and liability RREs that the compliance date for claim reporting is now extended from 4-1-10 until 1-1-11, effective immediately.
- All RREs should now be registered with the COBC, and either in or preparing for file testing. Data testing may continue during 2010, as needed.
- All data exchange testing will be completed by December 31, 2010. RREs that have completed file data exchange testing in place are encouraged to proceed to claim reporting data exchange status.
Chicago Workers Compensation Attorney -- 2-19-10
8/18/2009
Mandatory Insurer Reporting User Manual Released 8-04-09
We often report on important developments involving Medicare coordination with Illinois workers compensation claims. For those following the Mandatory Insurer Reporting requirements (MIR), the Centers for Medicare & Medicaid Services (CMS) released an updated Liability and Workers Compensation Insurance User Guide Version 2 dated 8-04-09. The 225 page document is offered to help insurance carriers and administrators understand upcoming claim reporting requirements for cases involving Medicare beneficiaries.
CMS also released an "Alert" dated 7-31-09 to define who is required to report under the new law -- that is anyone that CMS terms a Responsible Reporting Entity (RRE). The definition essentially boils down to any party that is responsible to pay the claim which may include the members of insurance risk pools, self insureds companies, any company with a deductible and workers compensation insurance carriers.
This document is in draft only and is subject to revision after additional public comment. It attempts to solve the double reporting problem with companies that keep deductibles or self insured retentions (SIR) and tries to define exactly who or what entity is responsible for the claim reporting.
Chicago Workers Compensation Attorney -- 8-18-09
8/12/2008
Mandatory Insurer Reporting (MIR): Medicare Secondary Payer Reporting
Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (PL 110-173) amends the Medicare Secondary Payer (MSP) provisions of the Social Security Act (Section 1862(b) of the Social Security Act; 42 U.S.C. 1395y(b)) to provide for mandatory reporting of insurance coverage for group health plans, liability insurance (including self-insurance), no-fault insurance, and workers' compensation. The new law imposes a reporting duty on carriers to report the identity of Medicare beneficiaries and coverage information to CMS for all those that are covered by "primary" plans like health insurance, or active claims under workers compensation or auto liability plans.
On 8-1-08 CMS released a Statement Summary listing Medicare mandatory reporting "data elements" listing required reporting details and the reasons behind implementing the requirements. Carriers must now notify CMS if a known Medicare recipient has a claim or coverage. Fines for noncompliance are $1,000 /day.
Compliance dates: -- January 1, 2009 information reporting for group health plans
-- July 1, 2009 reporting from liability insurance, no-fault insurance, and workers' compensation.
It is expected CMS will demand to be notified of all workers compensation settlements or all liability settlements for any Medicare beneficiaries so as to enforce the Secondary Payer Regulations, Medicare lien recovery rules and credits against future payments for injury related medical expense. Reporting requirements may also include (1) Nature of Injury, (2) Cause of Injury, (3) State of Venue, (4) ICD-9 primary diagnosis codes and (5) Specific Body Part involved. See the Statement Summary above for a detailed listing of data elements.
CMS created a central web page, Mandatory Medicare Insurance Reporting, for summary information regarding the updated carrier reporting requirements, updated memos and .pdf downloads.