Reporting Undocumented and Guest Workers

The industry is concerned about how to report Group Health Plan coverage or a payment, judgment or award of a liability, workers' compensation or no-fault to the Centers for Medicare and Medicaid Services.

CMS's response is straightforward -- an undocumented worker by definition does not have a Social Security Number (SSN) and is therefore not eligible for Medicare.  The industry should not report these individuals.

Guest workers with an alien number are not to be reported either.

The employer / insurer should monitor the undocumented / guest worker's status and if they do get an SSN and become Medicare beneficiaries, then the RRE must report any ongoing responsibility at that time.