Understanding the Exposure SCHIP Mandatory Insurer Reporting & MSP Compliance

Mandatory Insurer Reporting (MIR) Required on all NGHP (Liability, No-Fault, Self, WC)Required on all NGHP (Liability, No-Fault, Self, WC) Requires that primary payers check Medicare beneficiary status on ALL claims quarterlyRequires that primary payers check Medicare beneficiary status on ALL claims quarterly Requires reporting of ALL claims involving Medicare beneficiaries quarterlyRequires reporting of ALL claims involving Medicare beneficiaries quarterly Requires reporting S/J/As on ALL claims involving Medicare beneficiariesRequires reporting S/J/As on ALL claims involving Medicare beneficiaries “Contested” cases exception“Contested” cases exception Applicable regardless of whether or not future medicals are closedApplicable regardless of whether or not future medicals are closed

NGHP MIR Timeline RRE Registration between 5/1/09 and 9/30/09RRE Registration between 5/1/09 and 9/30/09 Only 1 reporting agent, TPA is not the RREOnly 1 reporting agent, TPA is not the RRE At time of registration, reporting date establishedAt time of registration, reporting date established Testing of MQF from 7/1/09 to 12/31/09Testing of MQF from 7/1/09 to 12/31/09 Ensures Medicare verification process works properlyEnsures Medicare verification process works properly Requires seven (7) fields of dataRequires seven (7) fields of data Testing of Production Files from 1/1/10 to 3/31/10Testing of Production Files from 1/1/10 to 3/31/10 Ensures 180+ field feed properlyEnsures 180+ field feed properly Requires massive claims system additionsRequires massive claims system additions 1 st live report between 4/1/09 and 6/30/101 st live report between 4/1/09 and 6/30/10 $1000/day/claim penalty begins$1000/day/claim penalty begins Retroactive reporting required from 7/1/09Retroactive reporting required from 7/1/09

RRE Registration Section 8 (pgs 22-26) NGHP User Guide Step 1: – Identify the Authorized Representative May not be an agent Must be able to contract on behalf of the RRE –Identify the Account Manager May be an agent of the RRE Controls the administration of the RRE’s account –Identify COBSW Users Manages the reporting process

RRE Registration Step 2: Determine Reporting Structure How many RRE IDs are you planning on obtaining? Multiple RRE IDs 1 RRE ID = 1 Reporting Agent = 1 Quarterly Report Multiple RRE IDs = 1 Reporting Agent = Multiple Quarterly Reports Step 3: RRE Registration on the COBSW PIN & RRE ID will be mailed to the Authorized Representative Step 4: RRE Account Set up on the COBSW May be done by the Account Manager Step 5: Authorized Representative Return Signed RRE Profile Report

ISAR MIR Workflow I dentify : Check Medicare status on all claims every monthI dentify : Check Medicare status on all claims every month S atisfy: Research/negotiate and resolve conditional payments prior to S/J/AS atisfy: Research/negotiate and resolve conditional payments prior to S/J/A A llocate : Future medicals in the S/J/AA llocate : Future medicals in the S/J/A R eport: On all Medicare eligible claims, report the MIR data to CMSR eport: On all Medicare eligible claims, report the MIR data to CMS

The OneSource Solution Solution for RRE should include:Solution for RRE should include: Meet the full scope of SCHIP requirementsMeet the full scope of SCHIP requirements Produce the proper MSP products:Produce the proper MSP products: In accordance with Gallagher Bassett protocolsIn accordance with Gallagher Bassett protocols Medicare Set-Aside Allocation (MSA)Medicare Set-Aside Allocation (MSA) Claims Settlement Allocation (CSA)Claims Settlement Allocation (CSA) Conditional Payment Research (CPR)Conditional Payment Research (CPR) Conditional Payment Negotiation (CPN)Conditional Payment Negotiation (CPN) Your cooperation is required to:Your cooperation is required to: Avoid $1,000/claim per day penaltyAvoid $1,000/claim per day penalty Reduce amounts paid for conditional paymentsReduce amounts paid for conditional payments Protect against future liability (MSA/CSA)Protect against future liability (MSA/CSA) Back-fill claims data to ensure MIR complianceBack-fill claims data to ensure MIR compliance

Selecting your Reporting Agent Data Integrity Cost Training Transparency Data Consolidation Risk/Rewards

Program Structure and use of RRE ID’s Client RRE using a Reporting Agent Client RRE using multiple Reporting Agents Client RRE self-administering

Post Registration Responsibilities Clients using Reporting Agents Clients Self-Administering and internally handling compliance with MMSEA 111.

Common misrepresentations of the Act Who is the RRE? What coverage and policy holders fall under Act? Captives, Insurance Pools, State Guarantee Funds? Carriers in receivership Exposure Claims/Occupational Dease

Fines/Penalties/Data Integrity Technology Requirements needed for compliance? Penalty situations When will fines be instituted?

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