The Centers for Medicare and Medicaid Services (CMS) have implemented new reporting requirements for any entity that pays a claim for medical benefits to a Medicare beneficiary. In most cases, companies with self-insured retentions or insurance deductibles are considered Responsible Reporting Entities (RREs) and are required to report to CMS about settlements or awards paid to Medicare beneficiaries to cover medical costs from liability, no-fault and workers’ compensation claims. These requirements are known as Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSEA), and they most likely apply to you if you have a deductible for your liability, workers’ compensation or no-fault insurance.
The requirements are being implemented in phases. The first step is to register with CMS on or before September 30, 2009. RREs must register by going to www.Section111.cms.hhs.gov, clicking on the “New Registration” button, and completing and submitting a registration application. Certain basic information will be required, including the company’s tax identification number, company name and address and contact information for the company’s Authorized Representative, who is an individual with legal authority to bind the organization to a contract and to the terms of Section 111 requirements and processing.
Before you register, you should determine how many accounts (RRE IDs) your company will need. For example, you may choose to have one RRE ID for submission of workers’ compensation claim information and another for liability and no-fault claims. You will be able to register for additional RRE IDs after September 30, 2009. Owing to the extensive reporting requirements necessary for each RRE ID, you should carefully consider the administrative requirements of managing multiple RRE IDs.
After your registration is completed, testing of data will begin, followed by live reporting. We will provide you with additional information about those steps. An enormous amount of information will need to be compiled and reported. Stiff penalties may be imposed for noncompliance in the future. The reporting process is adapted from the system used by group health plans, and does not translate seamlessly when applied to the private sector corporations that are now required to report. We look forward to working with you to prepare for ongoing compliance with Section 111 and answering any questions you may have.