"The purpose of the MSP mandatory reporting requirements is to help CMS determine whether a plan is primary to Medicare.... Responsibility for reporting falls upon the entity serving as an insurer or TPA for a group health plan, or, in the case of a self-insured, self-administered group health plan, a plan administrator or fiduciary.... [R]eporting is required for insured and self-insured major medical plans but not for health FSAs ... HRAs are generally considered to be group health plans that must be reported for MSP purposes[.]"  MORE >>