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May 15, 2009

Centers for Medicare & Medicaid Services Delays Registration and Reporting Deadlines for Medicare Secondary Payer

The Centers for Medicare & Medicaid Services just announced that it is extending the registration period and has published a registration reference guide. Also, the claim input testing period and the start date for initial reporting were delayed. CMS provided further clarification of exceptions related to total payment obligations to claimants and established the start date for the query function.

Registration

NAMIC has continued to request a delay in the registration deadlines because of the inability of insurers to meet the timetables for registration and reporting. In response to requests, CMS has announced a three month delay in the registration deadline. Insurers may now register between May 1, 2009, and September 30, 2009. In addition, CMS has clarified that if an insurer has a reasonable expectation that it will have no reporting obligations, that registration is not currently required. At any time that an insurer has a reasonable belief that claim reporting would be required, registration would be mandatory.

CMS also released a Quick Reference Guide for Section 111 Registration for all Responsible Reporting Entities. The attached guide is designed to assist Section 111 responsible reporting entities with the registration process.

Testing

Testing for the submission of the claim input file has been delayed. Insurers will be required to complete the testing process between January 1, 2010, and March 31, 2010. Once testing is completed for a required registered entity (RRE) ID, the system will set the RRE ID to a production status. However, testing may continue up until the first production claim input file is due. Test files will always continue to be accepted and processed after a production status has been attained.

Initial Reports

NAMIC has consistently pressed for a delay in reporting obligations to afford insurers additional time to revise data collection and retention procedures. CMS previously extended the initial reporting from July 1, 2009, to the first quarter of 2010. In response to requests for additional time, CMS has agreed to further extend the timeline to the second quarter of 2010. Insurers will be required to submit their first live production file no later than their assigned submission window for the April – June calendar quarter of 2010. However, if testing is complete, insurers may elect to file their initial report during their assigned period during the January – March 2010 quarter.

Query Function

The Medicare beneficiary query function will become available July 1, 2009, for RREs that have completed registration and are in testing status. Although registration is not required until September 30, query files may not be submitted until an RRE has completed the registration process. NAMIC raised concerns early in the process regarding the difficulties of verifying beneficiary status and requested insurer access to the beneficiary database.

Total Payment Obligations to Claimants (TPOCs)

CMS has agreed to delay reporting for TPOC amounts. Reporting will be limited to TPOC amounts on or after January 1, 2010. Likewise, TPOC amounts occurring prior to January 1, 2010, are excluded from calculating the amounts for purposes of the reporting thresholds.

NAMIC continues to work with CMS to address compliance issues, including mass torts and social security collection issues.

Direct questions to NAMIC Senior Federal Affairs Director Marliss McManus.

Posted: Friday, May 15, 2009 12:00:00 AM. Modified: Friday, May 15, 2009 2:40:38 PM.

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