Medicare Section 111 Non-Group Health Plan Reporting Date Extended to January 1, 2011

The Centers for Medicare and Medicaid Services (“CMS”) has announced that the date for required reporting by non-group health plans (“NGHPs”) under Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (“Section 111”) has been extended from April 1, 2010 to January 1, 2011.

Section 111, which added new insurer reporting requirements, was designed to ensure that Medicare remains the secondary payer when a Medicare beneficiary has medical expenses that fall under the primary responsibility of a group health plan, or a  liability, no-fault or workers’ compensation insurance plan (including those that are self-insured).  Under the Medicare Secondary Payer Act, Medicare can recover any conditional payments it has made that should have been paid by a primary insurance plan.

To view posted information from CMS on the extension of the NGHP reporting date, click here. 

CMS will issue additional updates during February, including the steps that Required Reporting Entities can take to ensure their ongoing compliance with the Section 111 reporting requirements.  The newest version of the “Section 111 NGHP User Guide” is also forthcoming.

To view media coverage of the NGHP reporting date extension from BusinessInsurance.com, click here.

Colodny Fass is actively monitoring this issue and will continue to update clients on new developments.

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