In a Town Hall audioconference held on May 12, 2009, the Centers for Medicare and Medicaid Services (CMS) announced two major changes to the Mandatory Insurance Reporting requirements under Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 for Non-Group Health Plans (NGHPs), including self-insured hospitals and captive insurers: an extension of the registration and reporting deadlines, and a change to the date from which one-time payments to Medicare beneficiaries will have to be tracked.
The timeline for registration, testing and reporting has been changed to reflect the following deadlines:
- Registration for NGHPs: May 1 to September 30, 2009 (previous requirement: May 1 to June 30, 2009)
- Testing for NGHPs: January 1 to March 31, 2010 (previous requirement: July 1 to December 31, 2009)
- Live Claims File Submission for NGHPs: During assigned seven-day window beginning April 2010 (previous requirement: assigned seven-day window beginning January 1, 2010)
Responsible Reporting Entities (RREs) will have to report one-time payments to Medicare beneficiaries that occur on or after January 1, 2010. The old threshold date for tracking and reporting one-time payments was July 1, 2009. This change does not alter requirements with regard to Ongoing Responsibility for Medicals, just one-time payments (including annuities and structured settlements). Neither of the two changes above affect CMS's right to Medicare Secondary Payer recovery, only the obligation to report the payment and statutory penalties for a failure to report required data to CMS (up to $1,000 per day per claim).