Community Impacts of CMS Mandatory Insurer Reporting

[Guest Ernest]

Community impacts of Mandatory Insurer Reporting

Section 111 of Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSEA) adds new mandatory reporting requirements for Group Health Plan (GHP) and Non-Group Health Plan (NGHP) liability, no-fault and workers compensation insurance.

MMSEA expands and mandates the Voluntary Data Sharing Agreements (VDSA) for electronic reporting, originally conceived as an exchange of GHP entitlement data for Medicare beneficiary entitlement data. For those insurers that are already reporting GHP through VDSA, the changes to the reporting requirements are minimal (one additional piece of data). Insurers that have never reported GHP, an estimated 50 to 70%, will find the way has been paved by their industry competitors. However, the entire insurer industry is facing new, and still changing, NGHP data submission requirements, file transfer changes and compliance issues.

To be clear as possible at the moment, CMS defines who must report GHP data as "an entity serving as an insurer or third party administrator for a group health plan... and, in the case of a group health plan that is self-insured and self administered, a plan administrator or fiduciary." This "Responsible Reporting Entity" or RRE has a broader definition for NGHP, but still insurers will shoulder most of the burden of reporting.

Currently, CMS has no plans to lighten the reporting requirements for self-insured / small business reporting.

from piattconsulting.com