Medicare Secondary Reporting Requirements for HRAs


Beginning 10/1/10, HRA plans are required to report on a quarterly basis all covered HRA participants and dependents that meet specific criteria.

The purpose of reporting is to enable CMS to correctly pay for health insurance benefits of Medicare beneficiaries by determining primary vs. secondary payer responsibility. The employee/dependent data helps to assure that claims will be paid by the appropriate organization at first billing.

CMS Reporting is required for HRA plans with any of the following parameters:

• Groups with 20 or more full-time or part-time employees.
• Groups with less than 20 full-time or part-time employees if a covered individual is receiving dialysis or has had a kidney transplant.
• Multi Group Health Plan – if at least one employer of the group has 20 or more employees, all employers must report unless approved for a small employer exception by CMS. (Note: this exception does not apply to reporting those already entitled to (covered under) Medicare or with End Stage Renal (ESRD).
• Multi Group Health Plan – if at least one employer of the group has at least 100 full or part-time employees, the MSP rules apply to all individuals entitled to Medicare on the basis of disability.
• If the employer’s annual benefit exceeds $1,000, then the plan must register and report any qualifying participant with an annual benefit greater than $1,000.

Employers must report the following types of covered employees:

• 55 or older as of 10/1/10, 45 or older as of 1/1/11.
• Any member entitled to Medicare regardless of age.
• Anyone with ESRD or who has had a kidney transplant regardless of age.
• No COBRA members are included unless ESRD.
• No members covered under a retiree plan unless ESRD.

** If an employee or dependent of an employee is entitled to or covered by Medicare, their HICN must be reported.

If your group has an HRA, please contact us and we will discuss the best course of action for your plan to comply.

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