| Reporting Requirements Delayed for the Medicare Secondary Payer Act
February 23, 2010
In continuation of our February article regarding the Medicare Secondary Payer Act, the Centers for Medicare and Medicaid Services ("CMS") announced it will delay Mandatory Insurer Reporting until 1/1/2011.
The stated reason for the delay is that the industry as a whole was not ready for the previous 4/1/2010 compliance deadline. The Medicare Secondary Payer reporting requirements are intended to support Medicare's position as the secondary payer and allow Medicare to collect for benefits paid to a beneficiary that should have been paid by a liability, no fault or workers' compensation plan.
Nevertheless, while reporting is delayed, the Responsible Reporting Entities ("RREs") must still begin collecting the information that will ultimately need to be reported. Claims and settlements involving Medicare beneficiaries during this interim period must still comply with the Medicare Secondary Payer Statute ("MSP") and will be reported to CMS if they meet requirements, on 1/1/2011.
As the reporting deadline delay was announced, the CMS also advised of the following: (1) file data exchange testing will continue; (2) all RREs should now be registered and must either be preparing for or in file testing status, which may continue during 2010 as needed; (3) the data exchange testing will be completed by December 31, 2010; and (4) RREs that have completed file data exchange testing are encouraged to proceed to production file data exchange status.
During the week of February 22, the CMS will post on their website the next version of the "User Guide" for RREs and other information relating to policy issues. Additionally, the CMS will post an update for all RREs describing the steps those RREs can take to ensure ongoing compliance with the Section 111 reporting requirements.
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