FPCA: SCHIP Section 111 Mandatory Insurer Reporting Updates–April 27

Implementation of the SCHIP Section 111 Mandatory Insurer Reporting Program is underway.  Some important dates and reminders are provided below for your reference.

• As a reminder, the electronic registration period for Responsible Reporting Entities (“RRE”) under Section 111 Liability, No-Fault and Workers’ Compensation, is May 1, 2009 through June 30, 2009.  
• RREs must register on the CMS Coordination of Benefits Secure Web site during this period, which may be viewed by clicking here.
• The testing period runs from July 1, 2009 through September 30, 2009, during which the transmission of test files is required.
• After completing the registration and testing requirements, a quarterly file submission timeframe will be assigned to each RRE, during which actual data files will be submitted.
• The RRE must report on all claims, where the injured party is/was a Medicare beneficiary, that are addressed/resolved (or partially addressed/resolved) through a settlement, judgment, award or other payment on or after July 1, 2009, regardless of the assigned date for first submission.
• The reporting requirement applies to both single payment obligations (regardless of whether the payment obligation is executed through a single payment, a structured settlement, or an annuity) as well as those situations where ongoing responsibility for medical payments exists, even where the initial acceptance of payment responsibility pre-dates July 1, 2009.

The latest SCHIP updates are available on the CMS Web site, which may be viewed by clicking  http://www.cms.hhs.gov/MandatoryInsRep/04_Whats_New.asp#TopOfPage.

Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (P.L. 110-173), adds new mandatory reporting requirements for group health plan arrangements and for liability insurance (including self-insurance), no-fault insurance, and workers’ compensation.

Should you have any questions or comments, please contact Jennifer C. Erdelyi at jerdelyi@cftlaw.com.

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