Mandatory Insurer Reporting Timetable Delayed for Some

On November 9, 2010 CMS Announced:   Revised Implementation Timeline for TPOC Liability Insurance (Including Self-Insurance) Settlements, Judgments, Awards or Other Payments
 

Medicare has delayed the required submission of Mandatory Insurer Reporting data for all Liability Insurance initial claims reports with no Ongoing Responsibility for Medical (ORM) involvement until 1/1/2012. Liability and Workers' Compensation claims with ORM have not been delayed and will be required to submit claims records in Q1 2011. All claims/settlements involving Medicare beneficiaries during this interim period must comply with the Medicare Secondary Payer Statute (MSP) and will be reported to the Centers for Medicare and Medicaid Services (CMS) if they meet the requirements.
 

Liability insurance (including self-insurance) Total Payment Obligation to Claimant (TPOCs) must be reported if the TPOC Date is on or after 10/1/2011. 
 

The current rule requiring reporting of Non Group Health Plan (NGHP) TPOC dates as of 10/1/2010 has been changed to 10/1/2011 but only for liability insurance (including self-insurance) TPOCs.
 

The reporting date requirements for TPOC Dates of 10/1/2010 and thereafter associated with no-fault insurance or workers' compensation claims remain unchanged.
 

The reporting date requirements as documented in the User Guide for all NGHP ORM remain unchanged.
 

Initial Claim Input Files for reportable claims continue to be due during the Responsible Reporting Entity (RRE's) assigned file submission timeframe for the first calendar quarter of 2011. RREs that have reportable claims must commence production reporting in first calendar quarter 2011 and will include liability insurance (including self-insurance) TPOC reporting in the first calendar quarter of 2012 for TPOC Dates of 10/1/2011 and thereafter.
 

Medicare has also extended the Interim Dollar Thresholds for all lines of insurance. The new extension gives relief to settlements in Liability and Workers Compensation cases with TPOC amounts under $5,000 and executed prior to 1/1/2013. The threshold falls to $2,000 in year 2013 to 2014; then drops again to $600 in 2014 through 2015.
 

CMS cautions that the obligation to protect Medicare's interests remains unchanged in all lines of business. While the reporting dates have been extended regarding Liability claims with TPOC only, workers' compensation cases and No Fault cases are unaffected.
 

Time during the delay should be aggressively utilized by liability RRE's and TPAs to improve processes and procedures regarding Mandatory Insurer Reporting and Medicare Secondary Payer Compliance.

If you chose a Reporting Agent who has been unable to successfully complete testing of the reporting requirement after more than 2 years of notice and development, now is the time to explore the options and make a change without penalty. Gould & Lamb is prepared to take on additional MIR clients immediately and can successfully integrate both small clients and large clients regardless of needs and system complexities.

Contributed by Gould & Lamb. Contact Kip Daniels, Vice President of Strategic Services, at kip.daniels@gouldandlamb.com  or 866-672-3453 x 1077.