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
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.