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11/21/2008   Work underway to comply with new Medicare Secondary Payer law

Starting Jan. 1, 2009, all carriers in the United States will be required to report specific group and member information to the Centers for Medicare & Medicaid Services (CMS) on a quarterly basis. In order to best comply with the new law, Regence will collect and report the following data:

  • Group subscriber and dependent Social Security numbers
  • Group tax identification number
  • A description of each subscriber's current work status
  • Group size as defined by Medicare
The law enables CMS to collect fines from carriers for non-compliance. Those fines are charged for each day of non-compliance per beneficiary and can be imposed retroactively.

As you know, we already collect and report some of this information to CMS. However, the breadth of this new law requires us to report additional information. As a result, we will need to ask groups and members for information they may not be accustomed to providing, such as subscribers' dependents' Social Security numbers.

While the law goes into effect on Jan. 1, 2009, we have until Jan. 1, 2010, to achieve full compliance. For the time being, we are following our standard procedures for new and renewing groups. However, we are quickly developing processes that will allow us to collect missing information for groups that are renewing or enrolling for January and February 2009 and to ensure full data collection from future enrollments and renewals. In the coming weeks, we will share with you detailed information on how that data collection will work for you and your group clients.

Meanwhile, we encourage you to share this information with your clients. To help you learn more, visit the CMS Web site.

If you have any questions, please talk to your Regence Sales contact.

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