How will CMS use this information?
What is IBC’s plan for collecting this information?
What is the process for collecting beneficiary information now?
Could you give me more information about the Social Security numbers you need?
What about members who choose not to give their Social Security number?
What happens if we don’t send you this information? Is there any kind of penalty?
What resources are available to me for more information?
What is the new regulation?
A new Mandatory Insurer Reporting Law (Section 111 of Public Law 110-173) requires group health plan insurers to report beneficiary and other information to the Centers for Medicare & Medicaid Services (CMS) that is required for purposes of coordination of benefits. Three key elements that will be required are:
In order for CMS to properly coordinate Medicare payments with other insurance benefits, CMS relies on the collection of this information from group health plan insurers.
How will CMS use this information?
CMS will use this information to determine the primary payer, which will help to avoid any claims processing errors.
What is IBC’s plan for collecting this information?
As addressed in the accompanying letter, IBC is taking a multiphased approach. First, during your enrollment submission process, please provide Social Security numbers for subscribers, spouses, and domestic partners added to your group. The second phase will require the collection of all Social Security numbers for subscribers, spouses, and domestic partners, regardless of enrollment date. More information regarding the second phase will be provided at a later date, as well as our plan for confirming employer group size information and employer TINs.
Which plans are affected?
This change affects all group medical lines of business, excluding Medicare, and both fully insured and self-insured customers.
What is the process for collecting beneficiary information now?
IBC has been providing CMS with this data for several years on a voluntary basis for members over 65. Most of the data is already captured by IBC in our administration of insured and self-insured accounts. However, not all of the data elements are currently captured or regularly updated.
Could you give me more information about the Social Security numbers you need?
We need the Social Security numbers for all subscribers, spouses, and domestic partners, regardless of age. This will also include Social Security numbers that we don’t have or those that we believe have incorrect information. Members who do not have a Social Security number, such as non-U.S. citizens, are not included in this requirement.
Why are you requesting all ages for Social Security numbers when CMS is requesting ages 55 and older (45 and older beginning January 1, 2011)?
We believe that asking for the Social Security numbers of all subscribers, spouses, and domestic partners, regardless of age, will make things simpler for you in the future. We won’t have to ask you to send incremental information as members age each year.
Also, collecting this information now will help to eliminate any potential claims processing delays if CMS disagrees with who should be the primary payer. If CMS has this information, it could positively affect your rates by establishing CMS as primary payer where appropriate.
What about members who choose not to give their Social Security number?
We understand that you may have employees and their dependents who are reluctant to give their Social Security number. We will work with you to ensure the privacy of this information or develop an alternative plan for these members.
What happens if we don’t send you this information? Is there any kind of penalty?
CMS is assigning a penalty of $1,000 per individual per day for noncompliance.
What about privacy?
IBC is committed to protecting your privacy. We are only providing Social Security numbers to CMS only to comply with this new regulation. Furthermore, we will continue to utilize our internal member identification number on all cards and communications as outlined to you in 2006.
IBC takes numerous steps to keep the personal information of our members confidential and to prevent the unauthorized release of or access to this information. All employees sign confidentiality statements regarding member information annually. And all contracted providers are required to maintain confidentiality of member information and records in accordance with applicable laws.
What resources are available to me for more information?
CMS has prepared a number of documents to explain these new reporting requirements. For more information, visit www.cms.gov.