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MSP Reporting Requirements for HRAs

The Centers for Medicare & Medicaid Services (CMS) has issued guidance on new data-reporting obligations for third party administrators of Health Reimbursement Arrangements (HRAs) under the Medicare Secondary Payer (MSP) rules. The MSP rules specify when a group health plan must pay primary and when it may pay secondary if an individual is covered under both a group health plan and Medicare.

CMS has indicated that HRAs are group health plans subject to the MSP rules. As a result, HRAs are required to comply with the mandatory reporting requirements beginning with the fourth quarter of 2010 (October?December 2010), which is later than the January 1, 2009 compliance date that applies to other group health plans that are subject to the MSP rules. The extension of the compliance date for HRAs was intended to give third party administrators and their clients time to gather the necessary information to report on HRA coverage.

The attached document outlines what Discovery Benefits is doing to comply and what it will ask its HRA clients to provide to meet the CMS requirements.

Form Type: Administrative
Categories: HRA

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