Sunday, April 14th, 2024 

Medicare Mandatory Reporting Deadlines Approach

COSO Treadway Commission Picture “... complying with the Medicare Mandatory Reporting Requirements and modifying your workflow.”

Alert: Deadline Delayed to January 1, 2011

Applicable plans (defined as liability insurance, self-insurance, workers compensation laws or plans, and health insurers) are required to report to the U. S. Secretary of Health and Human Services the identity of any claimant who is entitled to Medicare benefits. The reporting requirement is intended to help Center for Medicare and Medicaid Services ("CMS") to subrogate claims and obtain reimbursements for benefits already paid or deny payments in circumstances where primary or third parties should be making such payments.

For non-health insurers, claim settlements to Medicare beneficiaries after June 30, 2009 need to be reported to CMS designated Coordination of Benefits Coordinator ("COBC"). The first electronic submissions will be filed on a predetermined schedule between October 1, 2009 and December 31, 2009. After January 1, 2010 the reporting will be on a quarterly basis.

The deadline for health insurers is earlier with quarterly filings commencing after September 30, 2009. CMS recently announced that it is moving the first file production date for applicable reporting plans to January 1, 2011. Insurers already reporting are not affected by the deferral.

The required reporting record layout is currently being finalized so both claims workflow and information systems will need prompt modification. Under the Act, the failure to report the appropriate information could result in fines of up to $1,000 per day per unreported claimant.

The process after submission is that COBC will determine amount owed and attempt to recover those amounts from the claimants. If unsuccessful, the amounts may be collectible from the applicable plans. This contingency encourages plans to modify their workflow and settlement procedures, accordingly.

Our professionals are uniquely qualified to assist you in complying with the Medicare Mandatory Reporting Requirements and modifying your workflow. Contact us at (630) 243-0117 or email

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