An impending change in the Medicare Secondary Payer (”MSP”) recordkeeping system could slightly lighten group health plan reporting burdens.
Effective October 4, 2021, Section 111 record submissions will accept effective dates up to three months in the future for Group Health Plan (GHP) claims. Because Medicare entitlement records may have effective dates up to three months in the future, CMS is updating the COB&R systems to accept these future MSP effective dates.
When a S111 GHP record is submitted and the Medicare Beneficiary’s entitlement is in the future (up to 3 months) and there are no errors, the system will now create an MSP record with a future MSP Effective Date. For S111 GHP records, a future MSP Effective Date (up to 3 months) will be accepted for beneficiaries with both current and future entitlement start dates (i.e., for prospective enrollments).
For example, if a Responsible Reporting Entity submits an MSP record on 10/05/2021 and the beneficiary’s Medicare entitlement date is 01/01/2022, the Benefits Coordination and Recovery Center (BCRC) will now accept the Medicare entitlement date of 01/01/2022 as the MSP effective date.
Some health plans might find these new rules alleviate some of the burden of their reporting now or as part of an upcoming system upgrade.
This article is republished by permission of the author, Cynthia Marcotte Stamer. To review the original work, see here.
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About the Author
Recognized by her peers as a Martindale-Hubble “AV-Preeminent” (Top 1%) and “Top Rated Lawyer” with special recognition LexisNexis® Martindale-Hubbell® as “LEGAL LEADER™ Texas Top Rated Lawyer” in Health Care Law and Labor and Employment Law; as among the “Best Lawyers In Dallas” for her work in the fields of “Labor & Employment,” “Tax: ERISA & Employee Benefits,” “Health Care” and “Business and Commercial Law” by D Magazine, Cynthia Marcotte Stamer is a practicing attorney board certified in labor and employment law by the Texas Board of Legal Specialization and management consultant, author, public policy advocate and lecturer widely known for 30+ years working as an on demand, special project, consulting, general counsel or other basis with domestic and international business, charitable, community and government organizations of all types, sizes and industries and their leaders on labor and employment and other workforce compliance, performance management, internal controls and governance, compensation and benefits, regulatory compliance, investigations and audits, change management and restructuring, disaster preparedness and response and other operational, risk management and tactical concerns.
Widely recognized for her work with health plan, managed care and other heath insurance, health care and life sciences health and other data and technology and related matters, organizations, she has worked extensively with other employer, employee benefits, insurance, trade and other association, financial, transportation, manufacturing, energy, real estate, accounting and other services, public and private academic and other education, hospitality, charitable, civic and other business, government and community organizations. and their leaders, on health and managed care and other employee benefits, related program design, documentation, contracting, insurance, administration, technology, compliance and internal controls, investigations and defense, regulatory and public policy and related matters. Ms. Stamer also has extensive experience published and spoken extensively on these and other human resources, employee benefits, compensation, worker classification and other workforce and other services; insurance; health care; workers’ compensation and occupational disease; business reengineering, disaster and distress; and many other performance, risk management, compliance, public policy and regulatory affairs, and other operational concerns.
A former lead advisor to the Government of Bolivia on its pension project, Ms. Stamer also has worked internationally and domestically as an advisor to business, community and government leaders on these and other legislative, regulatory and other legislative and regulatory design, drafting, interpretation and enforcement, as well as regularly advises and represents organizations on the design, administration and defense of workforce, employee benefit and compensation, safety, discipline, reengineering, regulatory and operational compliance and other management practices and actions.
Ms. Stamer also serves in leadership of a broad range of professional and civic organizations and provides insights and thought leadership through her extensive publications, public speaking and volunteer service with a diverse range of organizations including as Chair of the American Bar Association (“ABA”) Intellectual Property Section Law Practice Management Committee, Vice Chair of the International Section Life Sciences and Health Committee, Past ABA RPTE Employee Benefits & Other Compensation Group Chair and Council Representative and current Welfare Benefit Committee Co-Chair, Past Chair of the ABA Managed Care & Insurance Interest Group, past Region IV Chair and national Society of Human Resources Management Consultant Forum Board Member, past Texas Association of Business BACPAC Chair, Regional Chair and Dallas Chapter Chair, former Vice President and Executive Director of the North Texas Health Care Compliance Professionals Association, past Board President of Richardson Development Center (now Warren Center) for Children Early Childhood Intervention Agency, past North Texas United Way Long Range Planning Committee Member, past Board Member and Compliance Chair of the National Kidney Foundation of North Texas, a Fellow in the American College of Employee Benefit Counsel, the American Bar Foundation and the Texas Bar Foundation and many others.
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