If you’re required to comply with the Medicare, Medicaid, and SCHIP Extension Act (MMSEA) of the Centers for Medicare and Medicaid Services (CMS) — and its Section 111 reporting requirements — things have the potential to get significantly more complicated. That’s because on December 11, 2020, The Provide Accurate Information Directly (PAID) Act was signed into law.
First, a little background: The PAID Act was written because lawsuits had been filed by Medicare Advantage Plans against insurers for double recovery and for failure to provide primary payment or reimbursement for qualifying charges. The PAID Act enable insurers to better identify claimants’ Medicare plans and to avoid unnecessary litigation.
On To the Clarifications
We say complicated because, responsible reporting entities (RREs) have to manage additional data from CMS, which they never had to manage before the PAID Act. More specifically, the PAID Act requires CMS to deliver Medicare Part C (Medicare Advantage Plans) & Part D information to help RREs resolve liens with Medicare. That, however, requires significant changes to Section 111 reporting systems. So, beyond your present system’s inability to access the new fields, without changes, many systems won’t be able to process the CMS query responses at all. This could bring your current Section 111 reporting process to a grinding halt and put your compliance with CMS at risk. Testing on the new Section 111 reporting requirements begin in September. Those new requirements go live in December. That means you don’t have much time to get ready.
We say potential because, while many companies don’t have the resources available to make the necessary changes to be ready, we do. MIR Express™, our secure system for managing your Non-Group Health Plan (NGHP) Medicare reporting is ready to handle CMS’s changes and to deliver all the valuable new information you’ll be getting from CMS right away. The transition will be painless, and you can undertake that transition on your timetable, not on CMS’s.
If you’re already using MIR Express, you don’t have anything to worry about. And if you’re not already using MIR Express, you still don’t have anything to worry about because you can get it and be using it well before the deadline.
We’re ready right now. Please let us know when you are. September and December are coming soon.