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Outline for Responsible Reporting Entities (RRE's) under Section 111 of the MMSEA

Written by: George Nicholas Wukovich

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REPORTING REQUIREMENTS:

MMSEA Section 111 RRE’s will have to report on all claims that are resolved or partially resolved through a payment on or after July 1, 2009, where the injured party in the claim is or was a Medicare beneficiary. THE NEW KEY ELEMENT IN A SECTION 111 REE’s CLAIMS PROCEDURE WILL BE DETERMINING WHETHER OR NOT AN INJURED PARTY TO A CLAIM IS OR WAS A MEDICARE BENEFICIARY. The CMS has developed a QUERY ACCESS System to be added to its Section 111 MMSEA website for RRE’s to use in determining the Medicare entitlement status of a claimant, based upon certain health information criteria. Under MMSEA Section 111, any RRE claim payments that are made and completed before July 1, 2009, are not required to be reported through the COBSW application. Any RRE claim that is resolved or partially resolved through a payment that is made after July 1, 2009, will be required to be listed on the RRE’s first live Section 111 report.

SECTION 111 PRODUCTION FILES:

Section 111 production files will include Claim Input Files and RRE Tax Identification Number (TIN) Reference Files. The TIN Reference File is submitted with the Claim Input File so that the RRE data associated with each TIN does not have to be reentered on every Claim Input Record. The Claim Input Files will include at least forty-five data points, organized by: injured party/Medicare beneficiary information; injury/accident/illness information; self-insurance information; plan information; injured party’s attorney/representative information; settlement, judgment, award or other payment information; and, additional claimant information (if applicable).

REGISTRATION AND ACCOUNT SET UP BY AUTHORIZED REPRESENTATIVE:

All Section 111 RRE’s must initially: determine their Reporting Structure; and, identify their Account Representative and their COBSW users (Account Manager, Account Designees and Agents). The RRE must then register, through the COBSW “New Registration” button, and identify the RRE’s Authorized Representative in order to obtain a new COBC-assigned Section 111 Reporter ID number (RRE IDs) and associated personal identification number (PIN), to be issued via letter from the COBC to the RRE’s Authorized Representative. If an RRE’s Reporting Structure will require more than one RRE ID for Section 111 reporting, then the RRE must repeat this registration process separately for each RRE ID. Authorized Representatives are individuals inamed by the RRE who have the legal authority to bind the RRE to a COBC Data Use Agreement contract and to the terms of MMSEA Section 111 requirements and processing. The Authorized Representative is ultimately accountable for the RRE's statutory compliance.

ACCOUNT MANAGERS AND ACCOUNT DESIGNEES:

It is important to note that Authorized Representatives, Account Managers and Account Designees all have differing duties and limitations under the MMSEA Section 111 reporting program. The RRE must also separately name or assign a single Account Manager for each RRE ID that is issued. When an RRE ID and PIN have been received by the RRE’s Authorized Representative, the RRE ID and PIN must be given to the Account Manager, who must then use same to set up the RRE account via the COBSW “Account Setup” button. During this part of the registration process, the Account Manager will create a COBSW Login ID and Password; enter account information and file transmission methods; and, supply information about the Agents who will be used as Account Designees to submit Section 111 reporting data on behalf of the RRE. Account Designees are named by the Account Manager to assist with RRE account management and data reporting. Account Designees can be either RRE Employees or RRE Agents.

PENALTIES FOR NONCOMPLIANCE:

MMSEA Section 111 includes a civil penalty of $1,000 per day for each and every Medicare beneficiary for which an RRE fails to comply with the new reporting rules and regulations enacted by the statute. The Implementation Deadline, under MMSEA Section 111, is July 1, 2009. All instructions for implementation and compliance will be available at or thorough the CMS website (www.cms.hhs.gov/MandatoryInsRep).

CENTERS FOR MEDICARE & MEDICAID SERVICES WEBSITE:

A more detailed and descriptive analysis of the COBSW Section 111 registration and account set up requirements, and reporting procedures, can be accessed and printed through the CMS website (currently published at "www.section111.cms.hhs.gov/MRA/help/how_to/GetStarted.htm"). An MMSEA Section 111 USER GUIDE (Version 1.0) was issued by the CMS on March 16, 2009, and is also available for downloading and printing from the CMS website. On March 20, 2006, the CMS issued an Alert for the Liability/No-Fault/Workers Compensation RRE’s advising of modifications to the USER GUIDE. It is anticipated that further Alerts will be issued by the CMS as the MMSEA Section 111 reporting rules and regulations are refined and revised in the future.