New Direct Data Entry Option Available for Mandatory Reporting by Non-Group Health Plan ‘Small Reporters’ Under Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007

The Centers for Medicare & Medicaid Services (“CMS”) have issued three recent Alerts regarding implementation of the reporting requirements of Section 111 of the Medicare, Medicaid and SCHIP Extension Act of 2007 (“Section 111”). 

The Alerts, issued on December 21, 2010, provide information about a new Direct Data Entry (“DDE”) option for reporting liability insurance (including self-insurance), no-fault insurance, and workers’ compensation (collectively referred to as Non-Group Health Plan or “NGHP”) information mandated by Section 111.  In addition, the Alerts explain how to register for DDE reporting and extend the DDE reporting start date to March 1, 2011. 

DDE is available to “Small Reporters,” which are Responsible Reporting Entities (“RREs”) that will submit 500 or fewer NGHP claim reports per calendar year. The DDE reporting option will allow Small Reporters to manually enter and submit NGHP claim reports online via the Section 111 Coordination of Benefits Secure Website (www.Section111.cms.hhs.gov), rather than submitting data via electronic Claim Input Files.

CMS has indicated that during the testing phase of the DDE system, “a number of issues arose that have proved too difficult to resolve in time for the January 10, 2011 implementation date.”  CMS therefore has moved the DDE implementation date to March 1, 2011.  This revised implementation date for the DDE option does not have any impact on NGHP RREs submitting claim reports via Claim Input Files.

Moving the DDE implementation date does not affect the retroactive reporting requirements of January 1, 2010 associated with claim reports for Ongoing Responsibility for Medicals (“ORM”), or the requirement to report no-fault insurance and workers’ compensation Total Payment Obligation to the Claimant (“TPOC”) amounts with dates on or after October 1, 2010.  RREs using the DDE reporting option must complete retroactive reporting by March 31, 2011.

For further details, the DDE option Alerts issued on December 21, 2010 can be viewed at the CMS NGHP Alerts website: https://www.cms.gov/MandatoryInsRep/10_MMSEA_111_NGHP_%20Alerts.asp#TopOfPage.

This information is intended to provide a general overview of the issues contained herein and is not intended, nor should it be construed, to provide specific legal or regulatory guidance or advice.  If you have any questions or issues of a specific nature you should consult with appropriate legal or regulatory counsel to review the specific circumstances involved.

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