CMS Clarifies HRA Reporting Rules
Wednesday, July 07, 2010
Health Reimbursement Arrangements (HRAs) are subject to a new reporting requirement on October 1, 2010, and the Centers for Medicare and Medicaid Services (CMS) recently explained more fully how Responsible Reporting Entities (RRE) should comply.
For HRAs, the RRE is the entity that pays and/or adjudicates claims and may perform other administrative services. Infinisource is the RRE for those clients that utilize Infinisource for HRA administrative services. The new reporting requirements are a result of the mandates in Section 111 the Medicare, Medicaid and SCHIP Extension Act of 2007 (MMSEA). MMSEA requires group health plans to report eligibility information on HRA covered employees and beneficiaries to CMS to ensure plans are complying with the Medicare Secondary Payer (MSP) rules.
In late May, CMS issued an alert on how this obligation affects HRAs. In late June, CMS held a two-hour conference call on issues related to group health plans. In early July, CMS posted the revised Group Health Plan User Guide, V3.1, dated June 25, 2010. Much of the discussion during the conference call was on HRAs.
Here are the highlights of the recent CMS guidance:
- Reportable data. RREs must report eligibility information on the following individuals:
- Employees and beneficiaries who are age 55 and older (age 45 and older starting with the first quarter 2011 file submission)
- Known Medicare and end-stage renal disease (ESRD) beneficiaries
- Data needs. MMSEA require the Social Security Number (SSN) or Medicare Health Insurance Claim Number (HICN) of all reportable individuals, including spouses. Also, RREs need the date of birth to determine the age threshold. An RRE’s inability to obtain the needed information will impact its ability to provide compliant HRA administration.
- Testing is now underway. RREs could start sending test HRA files on July 1, 2010. Infinisource is currently engaged in this process.
- First file submission likely to be small. For the initial fourth quarter 2010 file submission, RREs only report those HRAs that have a plan year that starts on October 1, 2010. RREs do not have to report individuals whose HRA coverage starts on October 1, 2010. These would be reported in the first quarter 2011 file submission.
- Non-reportable data. RREs do not need to report the following:
- Retiree-only HRAs
- Limited-purpose HRAs and Insurance Premium-only HRAs (as long as they do not provide benefits covered by Medicare)
- HRAs of employers with fewer than 20 employees where no one is a Medicare or ESRD beneficiary
- HRA participants with less than $1,000 of coverage on the first day of the plan year (this includes the annual contribution amount plus any carryover amount from prior years, even if the employer funds the HRA on a month-to-month basis
The MMSEA requirements are extensive for HRAs. Infinisource has been preparing for this mandate for over a year. With the cooperation of our HRA clients and participants, we anticipate that there will be no major issues with compliance. A copy of the May HRA Alert is available at: www.cms.gov/MandatoryInsRep/Downloads/GHPRREsReportingHRA.pdf. A copy of the revised User Guide is available at: www.cms.gov/MandatoryInsRep/Downloads/GHPUserGuideV3.1.pdf.