You may have received a letter from your insurance company by now, asking for the number of people that you employ, their social security numbers, and your business Tax ID number. All employers offering commercial (group) coverage, must report this information, due to the "Medicare Secondary Payer Mandatory Insurer Reporting Requirement", passed into law in July 2008. The goal is to reduce the amount CMS (Center for Medicare Services) spends by wrongly paying primary when they should be paying secondary. Medicare should always pay secondary for Medicare eligible employees, for businesses employing over 20 employees. The benchmark of 20 employees is not just those participating or eligible for the benefits, but total employed by you. For those of you with less than 20 employed, Medicare would be the primary insurer and the group insurance would be secondary. Again, the intent of this requirement is to reduce the amount that Medicare is responsible for paying, thus saving the tax payers money.
Beginning this month, the insurance companies must begin reporting to CMS, SSNs (Social Security Numbers) for employees and dependents aged 55 and older. The law identifies the group health plan carriers and TPAs as being the Responsible Reporting Entities (RRE), to gather the required data elements and report this to CMS on a quarterly basis. Much of this required data the carriers already have, but they are looking to update numbers and complete missing information. By 2011, CMS is looking for SSNs for employees and dependents aged 45 and older, therefore some insurers are collecting that now. If your employee is reluctant to share their SSN, you can reassure them that the insurance companies go to great lengths to protect their privacy. One can review these requirements by checking the website cms.hhs.gov/MandatoryInsRep/, to confirm that it is legal and appropriate to collect SSNs from employees and their dependents. If however, an employee still refuses, the RRE just reports with incomplete files, which at this time involves no penalty.
Your insurance company will and probably already has contacted you to begin collecting this data. It benefits us all to eliminate double payments for Medicare along with the fraud and waste that this program experiences.