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The Centers for Medicare and Medicaid Services (CMS) published Version 3.0 of the Non-Group Health Plan (NGHP) User Guide. Perr&Knight has completed an initial review of the document and found the following significant changes to the Medicare Secondary Payer reporting requirements:
- Mandatory production reporting of settlement data begins on January 1, 2011. (The original date was April 1, 2010.) RREs will report their first mandatory report during their previously-specified 1st Quarter, 2011 reporting period. (Example: Reporting Period 5 represents a reporting window of 2/1/2011-2/7/2011.) RREs can report settlement data as early as their 2nd Quarter, 2010 reporting period.
- RREs are now required to submit TPOC single settlements (single payments, annuities, etc.) that are settled on or after October 1, 2010. (The original date was January 1, 2010.)
- RREs are now required to submit settlements with on-going responsibility for medical payments if they are open/active on or after January 1, 2010. (The original date was July 1, 2009.)
CMS also published three companion alerts with this new User Guide. These alerts represent changes that did not make the current version of the User Guide; however, these documents are as official as the User Guide itself. These alerts are as follows:
- NGHP Required Reporting – Alert notifies RREs that additional guidance will be forthcoming on risk management write-offs, clinical trials, foreign insurers, and product liability reporting procedures.
- NGHP RRE Compliance – Alert further defining “reporting compliance” for companies.
- NGHP Who Must Report – Alert providing further clarification on which companies must comply with the MMSEA Section 111 reporting requirement.
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