CMS – Mandatory Eligibility Reporting
The Medicare, Medicaid, and SCHIP Extension Act of 2007(P.L. No. 110-173) extends federal funding to various federal programs; however, Title 1 "Medicare", Section 111 "Medicare Secondary Payer" requires an entity serving as an insurer or third party administrator for a group health plan and, in the case of a group health plan that is self-insured and self-administered, a plan administrator or fiduciary, to obtain from plan sponsor and plan participants certain information for the purpose of identifying situations where the group health plan is or has been a primary plan to Medicare. In addition these entities are responsible for submitting such information to Medicare beginning January 1, 2009.
Among the data elements required to be submitted are dependent social security numbers. This is probably the biggest challenge that insurers, plans and TPAs are facing. The law requires that for all individuals submitted, social security numbers be included . ABPA, is a Required Reporting Entity for those clients we process health benefit claims. As such, ABPA files quarterly reports with CMS. To ensure all data elements are reported, we continue to request information, including social security numbers from participants through enrollment cards and letters.
MEDICARE Part D
The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) added a new prescription drug program to Medicare known as Medicare Part D. The prescription drug coverage under this Medicare program became available on January 1, 2006.
Under the provisions, entities that provide prescription drug coverage to Medicare beneficiaries must disclose to these individuals and Centers for Medicare and Medicaid Services “CMS” whether the entity’s prescription drug coverage is creditable or non-creditable. A disclosure is required whether the entity’s coverage is primary or secondary to Medicare. ABPA assists several clients with the distribution requirements to Medicare beneficiaries and to CMS.
The subsidy provision of the MMA provide that an employer offering a qualified retiree prescription drug plan can apply to receive a tax-free subsidy equal to 28% of qualifying enrollees’ allowable annual prescription drug costs (after rebates, discounts or other similar price concessions).
On an ongoing basis ABPA assists clients with:
Distributing ongoing notices to Medicare Beneficiaries
Notifying CMS of the status of our clients prescription drug plans
Filing for subsidy applications, reconciliation and ongoing reporting
Completing and filing Authorized Representative Verification forms
Completing and filing any other forms that CMS develops