MMSEA Part 111 MSP Necessary Reporting, GHP Person Information, Model 6.2 (Rev. 2021/11 June); CMS Technical Alert: Inclusion of Half D Data in Part 111 Question Solely Response File for Accountable Reporting Entities (RREs) That Present Major Prescription Drug Data (June 28, 2021)
CMS has up to date its GHP Person Information and issued a technical alert on the Medicare Secondary Payer (MSP) reporting processes for prescription drug protection, which turned obligatory for accountable reporting entities (RREs) efficient January 1, 2020 (see our Checkpoint article). As background, sure insurers, TPAs, plan directors, and fiduciaries are required to report group well being plan protection info (which now contains details about prescription drug protection) for people who’re additionally entitled to Medicare. For insured plans, the RRE is usually the insurer, though if a TPA processes group well being plan claims for the insurer, the TPA is the RRE. For self-insured plans with TPAs, the TPA is the RRE, however employers that sponsor self-insured, self-administered group well being plans with out TPAs can also be RREs. Since RREs could not know whether or not a lined particular person is a Medicare beneficiary, RREs can ship CMS a question file to find out a person’s Medicare standing. The current CMS technical alert and up to date GHP Person Information notify RREs that present main prescription drug protection that efficient December 11, 2021, the question file format will embody the latest Medicare Half D prescription drug protection enrollment info for beneficiaries.
EBIA Remark: Employers could also be requested to help RREs in compiling details about plan contributors. And CMS has emphasised the significance of employer cooperation with their plans’ RREs, noting that employers that don’t present the mandatory info to the RREs are placing their insurers and TPAs vulnerable to noncompliance. For extra info, see EBIA’s Group Health Plan Mandates handbook at Part XXIV.J (“MSP Necessary Reporting Requirement”). See additionally EBIA’s Self-Insured Health Plans handbook at Part XXV.C (“Coordination of Advantages With Medicare, TRICARE, and Medicaid”); EBIA’s Consumer-Driven Health Care handbook at Part XXV.F (“HRAs and Medicare Secondary Payer (MSP) Necessities (Together with Necessary Reporting)”); and EBIA’s COBRA handbook at Part XXX.D (“Medicare Secondary Payer (MSP) Guidelines”).
Contributing Editors: EBIA Workers.