Compliance Questions -MSP Mandatory Reporting

November 2, 2011    
If a participant in a Health Reimbursement Arrangement ("HRA") is reimbursed his or her entire allocated benefit amount for the plan year before the end of the plan year, does the "responsible reporting entity" ("RRE")  have to report such termination of coverage to the Coordination of Benefits Contractor ("COBC") under the Medicare Secondary Payer Mandatory Reporting?

Yes. In an Alert released on September 27, 2011, the CMS Office of Financial Management/Financial Service Group indicated that a notice of termination has to be submitted to the COBC when an HRA insured’s HRA benefit coverage is exhausted and no additional funds will be added to the HRA for the remainder of the current plan year for the HRA.  A notice of the termination is to be provided to the COBC by including it in the RRE’s next regularly scheduled MSP Input File Submission.  The RRE may also call the COBC Call Center, at 1-800-999-1118 (TTY/TDD 1-800-318-8782), with the notice of the termination.

This new notice of termination requirement replaces language in Section 7.2.7 on page 67 of Version 3.2 of the GHP User Guide which had stated that a RRE was not required to submit a Termination Notice when the annual benefit value was exhausted, or only when coverage was not continued or not renewed in the subsequent  plan year.

In the next plan year when the participant is provided with an additional annual benefit amount, the RRE must submit a new record on the MSP Input File for each Medicare beneficiary that is an active covered individual and whose HRA annual benefit is $5,00 or greater.  The effective Date (Field 10) should reflect the start date of the new coverage period.

Please remember that effective October 3, 2011, only HRA coverage that reflects an annual benefit level of $5,000 or more is to be reported under the Medicare Secondary Payer Reporting Provisions.

For More Information:
If you have any comments or questions regarding any of above information, please do not hesitate to call (708) 717-9638 or e-mail
larry@larrygrudzien.com

Thank-You,

Larry Grudzien
Attorney-At-Law

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About rjoyner

Ric Joyner, CEBS, GBA, CFCI Customer Experience Officer Ric is a founder of eflexgroup.com a national web based TPA for Cafeteria, HRA, HSA, Transit, VEBA and COBRA plans. eflexgroup is a leader in self-service employee benefit systems. eflexgroup was the first TPA in the industry to go “online” in 1999 allowing employees to self-serve 24 hours per day. He has lead the industry with eflex by placing provable customer service statistics, live, on eflexgroup.com Ric is celebrating his 32nd year employee benefits. He helped create TPAs such as TASC and Employee Benefits Corporation in Madison WI. He was a licensed insurance agent for 29 years. The designations Mr. Joyner holds are; Certified Employee Benefits Specialist, Group Benefit Associate, Certified Flexible Compensation Instructor, board approved by ASPA to teach Cafeteria Plan regulations. Ric also has a bachelors of science in Information Technology and MBA (emphasis is project management) and graduated summa cum laude from Capella University with a 4.0. Ric helped found the National Association of Professional Benefit Administrators (NAPBA.org). NAPBA is dedicated to training administrators in best practices and grass roots lobbying. Ric has served in the past as the Wisconsin Association of Health Underwriters State President in 2003. Ric is a frequent speaker and article writer for prestigious associations such as NAHU.org, NAPBA.org, Wisconsin SHRM, Austin SHRM, PACE.org, International Foundation of Employee Benefits, Tampa Bay AHU, WI AHU, Florida AHU, Florida NAIFA and participates on the List Serves (compliance programs for Consumer Driven Products of NAHU and International Foundation of Employee Benefits)

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