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Employer with more than 20 employees wants to establish a health reimbursement arrangement that is limited to reimbursement of expenses for smoking cessation programs.

Would a limited purpose HRA of this nature still be subject to Medicare Secondary Payer Act reporting to CMS? Medicare does cover smoking cessation treatment, from what I could gather online, but surely this can be distinguished from a general-purpose "Group Health Plan" for reporting purposes?

That is my wishful thinking, however. Any comments or thoughts are appreciated.

  • 3 weeks later...
Posted
Employer with more than 20 employees wants to establish a health reimbursement arrangement that is limited to reimbursement of expenses for smoking cessation programs.

Would a limited purpose HRA of this nature still be subject to Medicare Secondary Payer Act reporting to CMS? Medicare does cover smoking cessation treatment, from what I could gather online, but surely this can be distinguished from a general-purpose "Group Health Plan" for reporting purposes?

That is my wishful thinking, however. Any comments or thoughts are appreciated.

It depends on the maximum amount that someone could receive under your plan. Right now, the trigger is $1000. So, if the maximum benefit available per covered employee, including any covered family member, is under $1000, you do not need to do the MSP reporting.

  • 1 month later...

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