Medicare Section 111

I’ve recently been working to help two clients comply with new Medicare reporting regulations. The regulation, MMSEA Section 111 – Medicare Secondary Payer Mandatory Reporting, requires anyone who pays for medical costs to report those payments to the federal government. The government will then compare the list of payees to their list of folks who receive Medicare payments. If there is an overlap, the government will look for refunds of the Medicare payments.

While you might think that this regulation only affects health insurers, the truth is that the scope is far larger. Our clients are not health insurers. One of them is a medical malpractice and workers compensation insurer. The other, believe it or not, is an auto manufacturer. The insurer is subject to this regulation because a portion of their settlements frequently covers the medical costs of the claimants. The auto manufacturer’s situation is more interesting. They are subject because, sometimes, when they pay out a product liability settlement, part of the amount paid is intended to cover the claimant’s medical costs.

Once you see how many companies are affected by this legislation you can get a sense of the total cost that its implementation will entail. Millions upon millions of dollars are being spent to make sure that affected companies are not subject to large penalties for noncompliance. In addition, it seems that many subject companies don’t yet realize that they are required to comply. For those who are subject, compliance is mandatory by Q1 of 2010 – so get to work!

How does Section 111 reporting relate to data warehousing? Well, in a couple of significant ways. First, complying with the regulation entails integrating data from a number of claims and payment systems into a single place from which it can be submitted to the government – just like a data warehouse integrates data from multiple sources. Second, if you already have a data warehouse, your compliance tasks may be much easier. One of our clients has a data warehouse in place that contains a lot of their claims data. We can, therefore, source this data from the warehouse and skip many of the integration and access issues we would otherwise encounter.

Are you under the gun for Section 111 compliance? Give me a call – we’ve got some cost effective ways to get you into compliance – quickly.

– Ben
734.761.5962 x503