Congress passed a law (section 6202 of the Omnibus Budget Reconciliation Act of 1989) to provide CMS with better information about the group health plan (“GHP”) of Medicare beneficiaries. The law required the Internal Revenue Service (IRS), the Social Security Administration (SSA) and the CMS to exchange information on whether each agency had the fact that Medicare beneficiaries or their spouses were working. The process of sharing this information has been called IRS-SSA-CMS data compliance. The purpose of the data match was to identify situations in which another payer, such as a PGH, should have paid all or part of a medicare fee. The voluntary sharing of voluntary data by the employer is another way to meet the requirements for data compliance. As part of this agreement, an employer communicates information about the coverage of the group plan with CMS. In return, CMS undertakes to provide the employer with information about Medicare authorizations for identified Medicare individuals. The Centers for Medicare – Medicaid Services (“CMS”) has suspended the requirement for employers to report IRS-SSA-CMS data. The data matching program was developed to help THE CMS identify Medicare-authorized individuals who also had access to employer-sponsored services.

The CMS data notification site has been closed and CMS no longer sends letters to employers requesting data from staff and participants. Under the program, employers were required to provide CMS with information about the health care of their Medicare-eligible workers and spouses. CMS would send a questionnaire to employers that would require the employer to provide certain data on participants. To meet the demand for data, the employer had to create an account at CMS. After the account was activated, the employer was required to provide information about its health plan and answer questions about the staff and participants involved. Although the IRS-SSA-CMS Data Match has been terminated, cms encourages employers to consider entering into a Voluntary Data Sharing Agreement (VDSA) with CMS to exchange 2012 and Medicare Internet Access Data. Some large employers have already entered into VDS with CMS to exchange coverage information. For more information about the VDSA program, click here on the Voluntary Data Sharing Agreement page. Second, when reviewing service contracts (particularly with the TPP for group health plans), employers should ensure that the APA is required to complete the reports. A timely report will help identify timely applications for brightness that have been improperly submitted to Medicare.

This can prevent further headaches for the employer on the street. This statement by insurers and TPAs has no direct impact on employers. However, employers should be aware of these reports for two reasons. First, CMS will know if an employee has PGP coverage. Therefore, if employers and workers have a medicare claim, Medicare`s employer may hear that they are seeking a refund.