Published March 2009
Important Update: Medicare Secondary Payer (MSP) Act – New 2009 Reporting Requirements for your Health Plan and HRA
On March 6, 2009 CMS granted an extension for the Section 111 reporting of HRA’s. Below is an excerpt regarding this extension taken directly from the GHP User Guide Version 2.2 dated March 6, 2009. To reference the GHP User Guide in its entirety please visit: http://www.cms.hhs.gov/MandatoryInsRep/Downloads/030609GHPNotice.pdf.
“The CMS considers a Health Reimbursement Account (HRA) to be a GHP product for MSP purposes. RREs will be required to include HRA programs in Section 111 reporting beginning with MSP Input Files submitted in 4th Quarter 2010 (October – December 2010). This extension is being implemented to allow RREs time to gather the necessary information to report on HRA coverage. CMS will provide further instructions on reporting HRA coverage at a later date. RREs are NOT to report HRA coverage information until the 4th Quarter of 2010.”
Why is CMS implementing an extension for HRA’s?
The extension is being implemented to allow RRE’s (Required Reporting Entities) additional time to collect the necessary data for the reporting requirements and further instructions will be provided at a later date.
How does this affect BASIC and our clients?
BASIC, as a Third Party Administrator (TPA) for HRA’s, will be required to comply with the reporting requirements for BASIC HRA’s beginning 4th quarter of 2010. If you have an HRA with BASIC we will continue to take a pro-active approach to collect the necessary data that must be reported. We will provide our clients with additional information as it becomes available.
To keep up to date on this requirement please visit CMS’s website: