The Second Quarter of 2011 is the mostly likely time that Responsible Reporting Entities need to report a Group Health Plan (GHP) Health Reimbursement Arrangement (HRA) to meet Medicare Section 111 Mandatory Insurer Reporting Requirements.  HRAs are generally effective for one year and their annual renewal often coincides with the first of the year.  If your HRA is in that boat, then you don't have to report until the second quarter of 2011 -- UNLESS your are going to add someone to your plan in the last quarter of this year.  As you'll not be sure no one will join your plan, you should immeadiately build or buy a reporting solution.  You only have a couple of months left to pick a solution and test your files.  Medicare requires you submit two files before you can begin production reporting next year.  The thing to remember is that a first time responsible reporting entity must test their CMS MSP file transmissions no later than in the first quarter in which their plans become effective. They can then report the following quarter to meet Medicare's MMSEA reporting requirements.  You must register as a Group Health Plan RRE in .  Don't forget: if you are going to report your Health Reimbursement Agreement under MMSEA, then your are an responsible reporting entity and you have to register as a Group Health Plan RRE in order to determine which week in the quarter you must report

There is also a common misconception about what an HRA RRE (including a third party administrator) has to report under Medicare Section 111.  The RRE is only required to report periods of HRA coverage.  They are not to report, as some less knowledgeable reporting companies and agents may lead some to believe -- each payment. Only RREs that are reporting under MMSEA Non-Group Health Plans (e.g., liability, workers compensation and no fault plans) have to report an individual payment as a total payment obligation to claimant.

Responsible reporting entities are not required to report policies (and their periods of coverage) under Mandatory Insurer Reporting if the annual benefit value is less than $1,000.  If unspent funds from a previous year roll into the following year and the annual benefit then equals or exceeds $1000, the RRE must report HRA in the following quarterly report.  If the funds are expended and drop back below $1000 you may terminate that period of coverage.  You should not send a delete record, which would, in effect, erase the earlier reported valid period of coverage.

At one point in the development of the Section 111 Mandatory Insurer Reporting User Guide, Medicare had excepted "embedded" Health Reimbursement Arrangement from reporting.  The thought was that Medicare would seek recovery from the Group Health Plan and the GHP RRE would pay the demand out of the right account.  That idea has been left by the wayside.  RREs and TPAs that administer GHP coverage and HRA coverage for the same employee, must report each record separately.

In summary, here are the do's, don'ts and things to consider for a Responsible Reporting Entities reporting Group Health Plan (GHP) Health Reimbursement Arrangements (HRAs) to meet Medicare Section 111 Mandatory Insurer Reporting Requirements.

DON'T: Report each payment made by the plan

DON'T: Report policies with less than annual benefit value of $1000

DON'T: Delete a previously reported plan

DO: Test no later than the quarter in which your plan becomes effective

DO: Read the GHP User Guide

DO: Read the June 24th 2010 GHP Teleconference Transcript

DO: Your home work before selecting vendor

Things to Consider: Your HRA plan is always, regardless of the amount of the annual benefit value, primary to Medicare.  Medicare can seek recovery from your plan, whether you report it nor not.  CMS may learn your plan is primary, even if you don't report it because providers are obligated to report other sources of insurance.

Things to Consider: Get the best advice and the best reporting solution (Medicare Consul Services)
and expert demand resolution services Medicare Consul Services.  We can have you up in a day and reporting as soon as you can give us the data!

Visit our web site often for current news and updates