CMS Conference Call

Medicare Set-Aside Blog on October 7, 2008
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SCHIP Implementation Guidance

During an October 1st conference call, Centers for Medicare & Medicaid Services (CMS) provided a basic outline of what Responsible Reporting Entities (RREs) for both Group Health Plans (GHPs) and non-GHPs (including Workers’ Compensation, Liability, Self-insurance and No-Fault Insurance) can expect in the coming months.

First and foremost, CMS emphasized that they are focusing on complete and accurate reporting and not the penalty phase of the Extension Act. For non-GHP RREs, a grace period of one year has been granted for identifying claimants who are Medicare beneficiaries and for whom the primary payment responsibility was established prior to 07/1/09. In an effort to assist RREs in identifying applicable claimants, CMS is currently consulting with counsel and investigating whether they can provide a system by which RREs can perform queries to determine whether an individual is Medicare eligible.

A timeline (available here) has been established to identify the times in which a RRE must register with the COBC through the Coordination of Benefits Secure Web site (COBSW). The COBSW has been identified as the portal through which all information will be submitted and communications will be received in response to submissions. Electronic registration for GHP RREs will run 04/01/09 – 04/30/09 and electronic registration for Liability, No-Fault, Self-Insured and Workers’ Compensation RREs is planned to take place 05/01/09 – 06/30/09.

Each RRE must register individually; registration by a designated agent for the RRE will not be permitted, but use of agents for reporting is permitted. The agent to be used must be identified during the registration period.

Upon registering through the COBSW, the RRE will be contacted by the COBC and assigned own dedicated Electronic Data Exchange Representative who will become the RRE’s personal contact at the COBC. The representative will work with the RRE and their technology staff to set up and test the data exchange process. The testing period for GHP is scheduled to occur 04/01/09 – 07/01/09 and will occur 07/01/09 – 09/30/09 for non-GHP RREs.

Once the trial has been determined to be successful, then the production phase will begin. GHP RREs will submit their first production files 07/01/09-10/01/09 and non-GHP RREs will begin submitting production files 10/01/09-12/31/09. The RRE or its agent will submit the required information and in return will receive both an acknowledgement of receipt and the COBC response file, which will notate any errors. These errors need not be corrected immediately, but in the next scheduled reporting. The COBC already has 200 firms completing daily exchanges and report that once established it is a very smooth process. More specifics regarding the type of information that is to be required will be published as the data element is still being developed for non-GHP.

Additional CMS sponsored Open Door Forum Teleconferences, User Guides and computer based training programs are expected to be released over the last quarter of this year. User guides for both GHP and non-GHP RREs are expected within the next 30 days.

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