Registration with the Centers for Medicare & Medicaid Services for applicable plans (including self-insurance, automobile, homeowners insurance; no-fault insurance; and workers’ compensation) related to Medicare Secondary Payer responsibilities must occur by September 30, 2009. CMS has clarified that if an insurer has a reasonable expectation that it will have no reporting obligations that registration is not currently required. However, at any time that an insurer has a reasonable belief that claim reporting would be required, registration would be mandated.
To help answer questions and assist NAMIC member companies with the registration and new reporting requirements, we have created a special Medicare Secondary Payer Resource Center on our website.
As you know, NAMIC has been working on this important issue for the last year and has held separate and joint industry meetings with CMS officials to address concerns with the requirements and to ensure that the reporting would not be overly burdensome for our members.
We were successful in working with the CMS to rectify a number of problems created by the reporting requirements. During the most recent meetings, CMS officials assured NAMIC that the agency’s emphasis will be on data collection and cooperation, rather than on the collection of fines and penalties.
Additionally, we were able to ensure that the reporting would be on a quarterly basis instead of a monthly basis and would be permitted at the discretion of the company, either on an individual company or consolidated basis, either directly or through a third-party reporting agent. Agency officials further indicated they would develop a self-certification form that insurers could use to collect information from claimants.
As September 30 approaches, we wanted to ensure that NAMIC member companies were aware of the deadline and had immediate access to all of the pertinent information in one convenient location.
If after viewing the website you still have questions or need additional information, direct questions to NAMIC Senior Federal Affairs Director Marliss McManus.