August 2009 CMS Alert/Update

http://www.cms.hhs.gov/MandatoryInsRep/Downloads/NGHHICNSSNNGHPForm.pd [...]
http://www.cms.hhs.gov/MandatoryInsRep/Downloads/ALERTComplianceHICNSS [...]

The Centers for Medicare and Medicaid Services (CMS) recently issued an Alert that contains compliance guidance for reporting entities under the Non-Group Health Plan (NGHP) Section 111 MMSEA Mandatory Reporting 42 U.S.C. 1395y(b)(8). Specifically CMS has recognized the difficulty many NGHP reporting entities are having in obtaining Social Security Numbers (SSN) from Medicare beneficiaries. As such, CMS has provided model language for NGHP reporting entities to utilize in their attempts to obtain the required information. The sample model language may be accessed at the FIRST LINK above.

Furthermore, CMS has indicated in the Alert that if a Medicare beneficiary refuses to furnish either their HICN or SSN as requested, and indicates their reason for refusal on the model language form, CMS will consider the reporting entity compliant purposes for the next Section 111 file submission. CMS Alert outlining NGHP reporting compliance requirement may be accessed by the following the SECOND LINK above.

As matters progress, Burns White will continue to provide updated information. In the meantime, please feel free to contact the Attorneys at Burns White, or Bruce McKnight, Medicare Marketing Director, at 412-995-3247 for any and all of your Medicare Set-Aside needs.