FPCA: SCHIP Mandatory Reporting for Group Health Plan Arrangements Forum Report: October 29

Oct 29, 2008

The Centers for Medicare & Medicaid Services (“CMS”) held its second public question and answer session (“Session”) today, October 29, 2008, to discuss mandatory reporting requirements related to Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (“SCHIP”).  To view the Session agenda, click here.

SCHIP adds new mandatory reporting requirements for group health plan arrangements, as well as liability insurance (including self-insurance), no-fault insurance, and workers’ compensation insurance. 

Discussion during the second Session was limited to audience questions regarding implementation of changes to non-group health plan (liability, self, no-fault, and workers’ compensation insurance) reporting requirements.  Group health plan arrangements were discussed during the first Session, which was held October 22.  To view a summary report of the October 22 Session, click here.

Questions raised during the October 29 Session mainly focused on:

  • Data reporting requirements
  • File formatting/record layout requirements
  • Handling of reporting persons without social security numbers or persons that refuse to provide them
  • Time-frames for the completion of reporting
  • Ability to make changes to filings
  • The date which a Medicare recipient’s information should first be reported
  • Issues unique to liability insurance
  • Health Insurance Portability and Accountability Act (“HIPAA”) confidentiality concerns
  • Reporting for Medicare recipients injured outside of the U.S.

Session leaders indicated that the number one question from both Sessions regarded reporting requirements for persons with no social security number.  Session leaders reminded attendees that those eligible to qualify for Medicare must have a social security number.

To view the CMS implementation plans for SCHIP as of June 1, 2008, as well as a brief overview of the provisions of the law, click here.

To view the Interim User Guide for non-group health plans, which lists the proposed file layouts and required record elements, click here.

 

Should you have any questions or comments, please do not hesitate to contact Colodny Fass.

 

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