Responsible Reporting Entity (RRE)

Deciding who is and who is not an RRE is not always straightforward for self-insured organizations.  Self-insureds in particular should review the "Self-Insured" sub-link to familiarize themselves with some of the variations.  If you need help, please feel free to contact Piatt Consulting for help.

Group Health Plans

(GHP) Arrangements (42 U.S.C. 1395y(b)(7)) -- Insurer
For purposes of the reporting requirements at 42 U.S.C.1395y(b)(7), an insurer is an entity that, in return for the receipt of a premium, assumes the obligation to pay claims described in the insurance contract and assumes the financial risk associated with such payments. In instances where an insurer does not process GHP claims but has a third party administrator (TPA) that does, the TPA has the responsibility for the reporting requirements at 42 U.S.C. 1395y(b)(7).

Third Party Administrator (TPA)
For purposes of the reporting requirements at 42 U.S.C.1395y(b)(7), a TPA is an entity that pays and/or adjudicates claims and may perform other administrative services on behalf of GHPs (as defined at 42 U.S.C. 1395y(b)(1)(A)(v)), the plan sponsor(s) or the plan insurer. A TPA may perform these services for, amongst other entities, self-insured employers, unions, associations, and insurers/underwriters of such GHPs. If a GHP is self-funded and self-administered for certain purposes but also has a TPA as defined in this paragraph, the TPA has the responsibility for the reporting requirements at 42 U.S.C. 1395y(b)(7).

CMS is locked into the GHP reporting requirements of 1395y(7)(A)  "...an entity serving as an insurer or third party administrator..."  Although CMS has not issued any written guidance, CMS has made it clear during subsequent teleconferences that the Insurer, not the TPA, is responsible for reporting, but may use a TPA as a vehicle for reporting -- editor

Non-Group Health Plans (Workers' Comp, Liability and No-Fault)

42 U.S.C. 1395y(b)(8) defines a responsible reporting entity (RRE) to be an applicable plan:
Applicable Plan - In this paragraph, the term `applicable plan' (e.g., trust --ed) means the following laws, plans, or other arrangements, including the fiduciary or administrator for such law, plan, or arrangement:

  • Liability insurance (including self-insurance).
  • No fault insurance.
  • Workers' compensation laws or plans.

Liability and No-Fault Insurer

The insurer may or may not assume responsibility for claims processing; however, the insurer has the responsibility for the reporting requirements at 42 U.S.C. 1395y(b)(8) regardless of whether it uses another entity for claim processing.

Workers' Compensation

The Federal agency, the State agency, or self-insured employer or the employer’s insurer.  Where such a plan is directly funded by the employer, the employer has the responsibility for the reporting requirements at 42 U.S.C. 1395y(b)(8). Where such a plan is indirectly funded by the employer, the insurer has the responsibility for the reporting requirements at 42 U.S.C. 1395y(b)(8).

When you need multiple Reporter IDs

A Responsible Reporting Entity is assigned a unique Reporter ID and a Reporter ID can only be used once a quarter to report to Medicare.  If your firm has the need to report more than once per quarter, then you must request multiple Responsible Reporting Entities (Reporter IDs).  For instance, if you firm has multiple Third Party Administrators because of different insurance types, volume or acquisitions, and each TPA needs to report each quarter, you must register multiple Responsible Reporting Entities.

Our software reporting solution, Medicare Consul Services, provides the means to manage one or multiple Responsible Reporting Entities and Reporter IDs.

Agents

For purposes of the reporting requirements at 42 U.S.C. 1395y(b)(7), agents may submit reports on behalf of :

  • Insurers for GHP, No-Fault or Liability Insurance
  • Self-insured entities for liability
  • Workers compensation laws or plans
  • TPAs for GHPs
  • Employers with self-insured or self-adminstered GHP plans

Accountability for submitting the reports in the manner and form stipulated by the Secretary and the accuracy of the submitted information continues to rest with each of the above-named entities.

Disclaimer -- Piatt Consutling and our staff cannot render legal, accounting or medical service.  We can only try to provide accurate and authoritative information in regard to the subject matter covered.  If legal advice or other expert assistance is required, the services of a competent professional in that area should be sought.