Group health plans are facing a major new data collection challenge.
Since Jan. 1, 2009, the federal government has required the insurers and administrators for plans over a certain minimum size to give it the information it needs to determine whether some Medicare beneficiaries also have employer-sponsored health coverage.
The minimum size is 100 full-time and part-time employees for filing information about disabled employees, and 20 employees for coordinating Medicare and group plan benefits for employees who may be age 65 or older, or who may have covered spouses who are over age 65.
However, there is no minimum size at all for employers and plans responsible for filing benefits coordination information for employees with end-stage renal disease, according to Jack Rovner, a partner in the health law practice group at Neal Gerber Eisenberg L.L.P., Chicago.
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Multiemployer group plans, such as union plans, made up entirely of very small employers are exempt, but, if even one of the employers has 20 or more employees, the entire multiemployer group must file the Medicare coordination information, Rovner says.
The reporting entities must submit the required information through the Web.
In practice, Rovner says, the rules will mean that health carriers and plan administrators will have to ask agents, brokers and consultants to help them get employers to come up with the names, ages and Social Security numbers of every dependent and every spouse of every plan member ages 45 and older.
Brokers and agents will “start getting pressure from the insurers they represent to make sure everyone knows they have to collect this data,” Rovner says.
Meanwhile, Medicare secondary payer rule guidance is still evolving, and it is not clear what employers and plans should do about infant dependents or foreign national spouses who do not yet have Social Security numbers, Rovner says.
During a town hall meeting held in October, CMS officials suggested plans should do what they can to get Social Security numbers or Medicare health insurance claim numbers from plan members affected by the reporting requirements, or get an affidavit from the individual stating that the individual does not have either a Social Security number or Medicare coverage.