SCHIP Services: Mandatory Insurer reporting
The Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA) was signed into law in December of 2007. The legislation impacts the handling of Workers' Compensation, Liability, Auto No-Fault, and Self-Insurers claims, defined by CMS as Non-Group Health Plans (NGHP). Effective January 1, 2011, NGHP insurers will be required to report substantial data to the Centers for Medicare & Medicaid Services (CMS). CMS has created a website to obtain additional information on MMSEA, also known as SCHIP Reporting and Mandatory Insurer Reporting (MIR).
http://www.cms.hhs.gov/mandatoryinsrep/
CMS' implementation timeline for MIR on NGHP claims is as follows:
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The Medicare Query Function is available as of 7/1/09 upon successful registration with CMS.
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After registration, insurers will begin testing of data feeds for MIR from 1/1/10 through 12/31/10, depending on assigned reporting dates from CMS.
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Initial live data feeds can begin on 4/1/10 through 6/30/10.
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The first required live data feeds will begin on 1/1/2011 through 3/31/2011.
The primary goal of MIR is to identify and enforce Medicare's Secondary Payer (MSP) rights through recovery of conditional payments and ensure that settlements, judgments, and awards adequately protect Medicare's interests. Failure to report in the time and manner as specified by CMS carries a $1000 per day per claim civil penalty.
Gould & Lamb has completed it's development of a comprehensive software solution (OneSource) that addresses both Mandatory Insurer Reporting (MIR) Requirements and Medicare Secondary Payer (MSP) Compliance.
The Gould & Lamb "OneSource" solution is the only fully-developed and integrated MIR and MSP compliance solution in the industry today. We do not bifurcate the MIR from MSP compliance, nor do we use external 3rd parties to handle our reporting processes. Our approach is to utilize the MIR data to automatically identify claims with MSP exposure (conditional payments and allocations), protecting our customers from potential fines, penalties, and litigation post-reporting to CMS. Proper due diligence is critical to ensure that the solution insurers choose is developed and ready to function before 10/1/09.
Contact our Strategic Services team to obtain a full proposal on SCHIP and MSP Compliance. Ask about iService if you can not modify your claims system to meet CMS reporting requirements. Reporting in accordance with the MIR program as defined by CMS addresses half of the problem, but creates a subset of new issues that MUST be resolved to avoid costly claims and potential litigation.
For additional information or to discuss MIR, contact:
Nick Collins: Vice President of Strategic Services
866-672-3453 x 1332
Update: CMS NGHP Alert - Risk Management details here
Update: CMS NGHP Alert - Compliance in Reporting details here
Update: CMS NGHP Alert - RREs/Who Must Report details here
Update: CMS NGHP Alert - Technical Update details here
Update: CMS NGHP Alert - Foreign RRE Registration details here
Update: CMS NGHP Model Language Form for SSN details here
Update: CMS NGHP Alert - Who/What entity is an RRE details here
Update: CMS NGHP Alert - Authorized Rep Determination details here
Update: CMS NGHP Alert - Periodic Payment details here
Update: CMS NGHP Alert - Important Timeline Changes details here
Update: CMS NGHP Alert - Add'l TPOC fields details here
Update: CMS NGHP Alert - Reporting Thresholds details here
Update: MMSEA Section 111 NGHP User Guide available here
