CMS Mandates Insurer Reporting of Employee and Dependent Information

Beginning January 1, 2009, the Centers for Medicare and Medicaid Services (CMS) will require insurers and/or third party administrators (TPAs) of group health plans (as well as plan administrators and fiduciaries of self-insured and self-administered group health plans) to report certain plan participant information for the purposes of coordination of benefits. As a result, insurers and TPAs will need to gather and report information such as: subscriber and beneficiary names (and relationship to subscriber), Social Security numbers (primary and dependent), type of insurance coverage, and reasons why the group health plans are primary for each employee.

Since it is the responsibility of the insurer/TPA (and not the employer) to meet the filing deadlines and requirements specified by CMS, many carriers are contacting employers to request this information, while new and renewal applications include requirements for employee and dependent Social Security numbers.

Failure to report eligibility data and Social Security numbers as outlined above may subject the required reporting entity (insurer, TPA, employer and/or plan administrators) to civil monetary penalties up to $1,000 for each day of noncompliance for each individual for which data exchange is required.

CMS has posted information on its website regarding these new mandatory reporting requirements and the Medicare Secondary Payer program. If you have any questions about these new requirements, please contact our office at 919-403-1986.

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November 25, 2008

Hill, Chesson & Woody Employee Benefit Services

194 Finley Golf Course Rd, Suite 200,
Chapel Hill, NC 27517
Phone: 919.403.1986
Fax: 919.913.0237

www.hcwbenefits.com