Managing the complexities and achieving compliance
What is Section 111?
Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSEA) requires group health plans (GHP) and liability (including self-insurance), no-fault & Workers’ Compensation insurance to determine Medicare entitlement of their members and report on those active covered individuals to Medicare. The quarterly reporting will help the Department of Health and Human Services (HHS) identify situations where the group health plans or no-fault, liability and Workers’ Compensation and self-insurers, not Medicare, should be the primary payer for participants entitled to Medicare. For plans that do not have an existing VDSA/VDEA with CMS, electronic registration is from 4/1/2009 to 4/30/2009 via the Coordination of Benefits’ (COB) website. Liability (including self-insurance), no-fault & workers’ compensation insurance plan registration begins 5/1/2009 and end 6/30/2009.
In exchange, the Coordination of Benefits Contractor (COBC) will provide payers with the Medicare entitlement information for those individuals in the payer plan that can be identified as Medicare beneficiaries. Detailed information about Section 111 and its implementation can be found on CMS’s website through the links referenced below.
Challenges and the silver lining
Although Medicare-eligible members are only a small portion of payers’ overall membership base, management of these members can require system modification and increased administrative costs in 2009 and 2010. Section 111 reporting presents significant challenges in data collection & exchange, system and coordination of benefits process modifications, reconciling potential conflicting information and responding to anticipated increase in Medicare demand letters. The initial and ongoing effort could consume the time and focus of multiple resources.
However, there is a potential silver lining. Section 111 allows the reporting entity to query the Medicare Eligibility Database to identify Medicare entitled/enrolled members. Consultants report that approximately 700 to 2,000 out of every 100,000 members under the age of 65 are not identified by a health plan.* There are prospective savings due to early and efficient identification of Medicare members who were previously difficult to identify. Increased use of crossover claims make it more cost effective with a focused identification of the primary and secondary payers.
So where can we go from here?
Emdeon is working together with payers to provide a service that quickly and cost effectively enables payers to meet the MSP mandatory reporting obligations. Payers can meet the Section 111 reporting mandates by leveraging Emdeon’s experience in data hosting, electronic data interchange and history of successful partnerships with government and commercial payers. Have questions or are interested in more information on Emdeon’s Section 111 Medicare Secondary Payer Mandatory Reporting service? Email one of our product management experts, Sanju Pratap.
Other useful links:
MMSEA Section 111 Reporting
Mandatory Reporting Registration Resource
*Source: Huron Consulting Group
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