Rumor on the street is that some Group Health Plan (GHP) Health Reimbursement Arrangement (HRA) administrators are not stepping up to meet their Medicare Section 111 Mandatory Insurer Reporting Requirements.  Apparently, their rationale is based on, "How is Medicare going to find out?"  The short answer is that your covered life is going to let let the cat out of the bag.

Health care providers are required by statute to have in place a method for determining if a Medicare beneficiary has alternative insurance before they are allowed to bill Medicare.  Providers can be fined up to $2,000 for providing inaccurate information relating to the existence of other health insurance or coverage, so providers generally require the patient to complete a Medicare Secondary Payer Questionnaire before they will treat them.  If the beneficiary refuses to answer the questionnaire, his claims will be denied.  If the beneficiary does not cooperate with Medicare in identifying an alternative insurance plan, Federal regulations provide for Medicare to take action against the beneficiary.

Once the beneficiary identifies their alternative insurance, an HRA in this case, the information is reported by the provider to the Coordination Of Benefits Contractor (COBC) .  The very same COBC that is in charge of processing Medicare Section 111 Mandatory Insurer Reporting.

The bottom line is that your insured is the the most likely source of informing Medicare of your failure to report.  Proper reporting is cheap insurance compared to Medicare's $1,000 per day per beneficiary fines.

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