Insights

Updated MSP User Guide Addresses New Medicare Beneficiary Identifiers for Reporting


CMS recently updated its Section 111 MSP Mandatory Reporting GHP User Guide. As background, the Medicare Secondary Payer (MSP) Section 111 reporting requirements require group health plans to report to CMS regarding the coverage they provide. The reporting is meant to assist CMS in determining coordination of benefit (COB) responsibilities between the plan and Medicare. The requirement to report is generally on the insurer (for fully insured plans) and on the TPA (for self-insured plans). If an employer sponsors and self-administers a self-insured plan, it's the responsible party for Section 111 reporting.

In the updated MSP User Guide, CMS provides high-level guidance regarding the new Medicare Beneficiary Identifier (MBI). CMS has been in the midst of adding new Medicare cards that contain the MBI. The MBI is a unique number assigned by CMS to the individual and is meant to replace the current system, which uses Social Security-based numbers (which are known as Health Insurance Claim Numbers, or HICNs). Insurers and TPAs use the identifying number when reporting participant information via the Section 111 requirements. While CMS encourages the use of the new MBI, CMS will still accept a full Social Security number or an HICN for Section 111 reporting purposes. However, it's important to note that all reporting fields that previously contained "HICN" have been changed to "Medicare ID" (although they'll accept either an HICN or the new MBI). The related instructions have also been updated with information relating to the HICN.

The user guide contains no specific change regarding employers' obligations. Employers with fully insured plans or with self-insured plans administered by a TPA can continue to rely on the carrier or TPA for Section 111 reporting. However, employers with self-insured, self-administered plans should review the user guide.

Updated MSP User Guide »