The Centers for Medicare and Medicaid Services (CMS) in an alert posted to its web site on September 10th released new policy effective January 5, 2015 that provides increased flexibility to employers and WC plan administrators to submit Section 111 reports to CMS.
The alert responds to Section 204 of the Strengthening Medicare and Repaying Taxpayers Act of 2012 (SMART Act) by modifying the existing requirements related to the submission of HICNs and SSNs when NGHP RREs report settlements, judgments, awards, or other payments.
Effective January 5, 2015, where a NGHP RRE cannot obtain an individual’s HICN or full SSN, RREs may report the following data elements that will enable CMS to properly identify a Medicare beneficiary:
- Last five digits of SSN,
- First Initial,
- Date of Birth, and
If NGHP RREs are unable to obtain or do not provide the HICN, full SSN, or any of the above listed data elements, they must document their attempts to obtain this information. (RRE’s may use the model language provided by CMS located in the Downloads section of the Mandatory Insurer Reporting (MIR) for NGHP page at http://go.cms.gov/mirnghp.)
CMS indicated that a subsequent Alert will be published prior to the January 5, 2015 implementation, which will include additional instructions for entry of the partial SSN into the Claim Input File or Query Input File.
The information included in the Alert supersedes the applicable language in the MMSEA Section 111 Medicare Secondary Payer Mandatory Reporting Liability Insurance (Including Self-Insurance), No-Fault Insurance, and Workers’ Compensation User Guide (Version 4.2) and the MMSEA Section 111 Coordination of Benefits Secure Website (COBSW) User Guide (Version 7.6) and will be incorporated into subsequent versions of these User Guides.
The complete Alert is available at http://www.cms.gov/Medicare/Coordination-of-Benefits-and-Recovery/Mandatory-Insurer-Reporting-For-Non-Group-Health-Plans/Downloads/Change-in-Reporting-of-Medicare-Health-Insurance-Claim-Numbers-HICNs-and-Social-Security-Numbers-SSNs-for-Non-Group-Health-Plan-NGHPResponsible-Reporting-Entities-RREs-.pdf