As a reminder, service providers and third-party administrators (TPAs) must engage in mandatory Medicare reporting to ensure that the Medicare Secondary Payer (MSP) Rules are properly followed.
Employer Responsibilities
While the employer is only directly responsible for reporting if it self-administers a self-funded health plan, the employer will want to cooperate with its third-party vendor by responding to information requests in a timely manner.
Vendor Information Requests
The vendor might, for example, need assistance gathering dependent social security numbers. For more information, see Mandatory Insurer Reporting (NGHP) | CMS.
Penalties for Failure to Provide Necessary Information
The penalty for failure to provide information to the HHS Secretary that identifies situations where the group health plan is, or was, a primary plan to Medicare, pursuant to the reporting obligation, is $1,474 per failure.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.